rc11hill.governmentprograms
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Mortgage Bankers Association
Regulatory Compliance
Conference 2011
Government Program
Requirements
September 26, 2011
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Index
FHA Strategic Priorities
Performance Snapshot
Policy Development Priorities Appendix
Implemented FHA Policy Changes
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FHA Strategic Priorities
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FHA Strategic Priorities
FHA strategy and priorities have remained consistent
Stabilizing the housing market during this economic
recovery and assisting homeowners to avoid foreclosure
Ensuring the continued fiscal health of FHA and
strengthening risk management
Ensuring responsible access to credit and liquidity,
particularly for underserved communities
Enable responsible lending in a manner that is sustainable
for FHA and for borrowers, protects the tax payer and
facilitates return of private capital
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Stabilizing the Housing Market -
Avoiding Foreclosure
FHA has been at the forefront of supporting loss mitigation efforts
Programs supporting conventional and FHA mortgages
FHA specific programs
Administration foreclosure mitigation programs have helped more
than 5 Million homeowners avoid foreclosure since April, 2009 FHA Mortgages - Lenders are required to offer a range of FHA loss
mitigation tools to FHA borrowers
More than 450,000 FHA borrowers have retained their homesthrough these programs
FY2010 FHA servicers assisted 552,000 homeowners;completed final delinquency cures for 183,000
FY2011 (3 Qtrs.) FHA servicers assisted 493,000homeowners; completed final delinquency cures for164,000
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Stabilizing the Housing Market
Avoiding Foreclosure
FHA outreach to servicers
Lender visits initiated in February, 2010
Identify best practices to share with industry
Housing Counseling 2,759 HUD-approved counselors provided services to more
than 2.1M clients (as of 4/4/11)
909 Certified Counselors (as of4/4/11)
FY2011 Continuing Resolution eliminated HUD housingcounseling grant funds
Aggressive effort by FHA to convince congress to reinstatecounseling funding
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FHA Fiscal Health
Strengthening FHAs Risk Management structure
Unprecedented policy, process and risk control changes overthe last 2 years Credit Policy
Risk Management
Lender Approval
Lender Enforcement and Oversight
Servicing Performance
Loss Mitigation
Ensure that those who buy a home today can maintain thatobligation over the long term
Continue to support FHA reform legislation that would furtherenhance FHAs enforcement capabilities, risk managementefforts and flexibility to respond to the market.
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Performance Snapshot
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Performance Snapshot
FHA Fiscal Health Large and strong FY 2009/2010 books of business are stabilizing the fund
2010/2011 books are producing increased MMI premiums and historically high
credit quality (Q3 2011 highlights)
Higher credit scores
97.2% of Q3 2011 transactions have credit scores of 620 or higher compared to
50.4% below 620 in Q1 2008
The percentage of credit scores of 720 or higher is 4 times the Q1 2008 level
Lower LTVs - 24.4% of loans had LTVs below 90% v. low of 15.8% in Q4 2008
Delinquency Rates
Lower seriously delinquent rate (Q2 2011): 8.31% down from 9.05% one year ago
Decrease in early period delinquency rate (2010 book of business): .41% v. 2.54%for 2007 and 1.01% for 2009.
Overall delinquency rate is at lowest level in more than 5 years
Less than 10% of seriously delinquent loans in FHA portfolio are now less than 2
years old compared to 30% in 12/2009.
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Performance Snapshot
Volume and Market Share
Total active, insured SF Portfolio
7.26 million loans , over $1 Trillion dollars
Projected 2011 Application Volume (Forward Mortgages)
1.2 M endorsements totaling $220 Billion
Market Share 3% in 2005/2006 to 20% in 2008, 2009 and 2010 - Peaked at 28.7% in Q3 2008
Purchase loan share peaked at 47% in Q2 2010 with final expiration of first
time homebuyer tax credits
July 2011 - 76% of purchase transactions were for 1st time homebuyers.
Currently FHA accounts for 17% of total market share 30% of purchase market and 10% of refinance market
Volume down more than overall market during FY 2011
Down 32% over first 3 quarters from the year-earlier period compared to 14%
for overall mortgage market
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Policy Development Priorities
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Policy Development Priorities
Loan Limits new loan limits effective 10/1/11
MBA Q and A session (9/27 from 12:00 1:30 PM)
Exceptions for Credit Approved transactions and FHA to FHA
refinances
Lender Insurance Final Rule
Expands FHA authority to require indemnifications, additional
requirements re: performance monitoring and eligibility and
process for LI mortgagees that have undergone corporate
restructuring
Condominium Approval and Recertification Guidelines
Rule Making
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Policy Development Priorities
Underwriting Guidelines - Manually Underwritten Loans
Reduction of Maximum Seller Concessions
HECM rule making to address issues related to Property
Charge (T&I defaults)
Financial and Credit Capacity Assessment at origination
Additional flexibility and options for lenders to ensure
ability to pay property charges
Limit on funds advanced by lenders for delinquentproperty charges
Servicing requirements
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Policy Development Priorities
Automated Fraud and Risk Tools and Infrastructure
Total Scorecard Review
Consistency across 4 HOCs and Headquarters
Miscellaneous Policy Updates
2-4 Units
Refinance policies
Funds to close, Identity of Interest, DisputedAccounts, Self Employed Documentation
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Appendix
Implemented FHA Policy Changes
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FHA Fiscal Health
Implemented Policies Mortgage Insurance Premiums
Increased Upfront MIP to 2.25% (1/12/10)
Upfront premium reduced to 1% from 2.25%; annual premium
increased to 85/90 bps. depending on LTV (10/4/10)Results in approximately $300 M per month in value to the MMI fund
Annual premium increased 25 bps. (4/18/11)
LTV/FICO Changes (10/4/10)
Minimum 500 FICO
>580 eligible for max financing
500-579 limited to 90% LTV
Refinance Program Policy (4/18/11)
Clarifications and changes to streamlined and standard Refi
programs
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FHA Fiscal Health
Implemented Policies
Lender Approval Policy (5/20/11)
Higher Net Worth Requirements (5/20/10)
Discontinue loan correspondent program; focus oversight
on lenders with greatest responsibility for loan (1/1/11) Lender Monitoring Policies
Mortgagee Eligibility and Electronic Recertification
Requirements (11/17/10)
Quality Control Requirements - Sponsored Originator, LoanSales (1/05/11)
Audited Financial Statement Reporting Requirements for
Parent/Subsidiary Structures and Multifamily Mortgagees
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FHA Fiscal Health
Implemented Policies HECM Program (10/4/10)
HECM Saver lower upfront premium (.01%) with lower max principal
limitWill significantly reduce risk ARM Loans with lower initial draws, higher
appraised values; using program as a financial planning tool
HECM annual MIP increase to 1.25%Principal Limit Factors changes which result in lower maximum
principal limits
HECM Property Charge Loss Mitigation - Guidance for existing
delinquencies (ML 2011-01 published 1/3/11)
Requirements for reporting delinquenciesEmphasis on Loss Mitigation
Due and Payable Approval Process
Additional funds allocated for housing counseling
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FHA Fiscal Health
Implemented Policies Condo Guidelines
Temporary guidelines were extended through 6/30/11 (ML 2011-03 published
11/09)
Condo Recertification and Approval Process introduced (12/10) - Requires project
re-approval and recertification for 25,000 plus condo projects
Mortgagee Letter and Guidebook published 6/30/11
H4H Termination (ML 11-20 published 6/10/11)
Program expires 9/30/11; loans must be endorsed on or before that date
Last date for assigning case numbers was 7/20/11
Maximum Loan Limits (ML 11-29 published 8/19/11: effective 10/1/11)
Operational Process Improvement throughout FHA (ongoing) One HOC, four locations
Training and Outreach
Internal Processes to support pace of change, ability to effectively execute
New, improved HMID Meetings with HOCs
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