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I just read a very troubling analysis of some potential problems with the FHA mortgage insurance program that I would like to draw your attention to. The blowback from these problems could lead to massive problems in the real estate markets, the failure of many more lenders (including some of the largest), and much more stringent guidelines for future FHA insured mortgages.
The passage of HR 5981 has given FHA the authority to raise annual mortgage insurance rates on FHA loans. The FHA annual insurance premium is the amount charged yearly and divided evenly between that year’s mortgage payments. HUD asked for this authority in order to facilitate lowering the FHA Upfront Mortgage Insurance Premiums which are added to the loan amount at the time of closing.
The FHA Streamline Refinance program has helped many borrowers lower their interest rates and housing payments. FHA has long held the view that decreasing a borrower’s monthly payment should be a good thing and very easy to accomplish as long as the borrower has been making their payments on time. After all, if the borrower is already making the payments and FHA has already insured the mortgage either way, then why be picky about the details. Thus, the FHA streamline refinance process has always been an easy one.
At one point in time, Taylor Bean & Whitaker (TBW) was the “go to” FHA lender for many thousands of mortgage brokers and community banks across the country. For many community banks, TBW was the only mortgage lender in the game.
As a result of this TBW grew to be one of the largest privately held mortgage lenders in the country. Many thousands of people own their homes today because of TBW.
As proposed in a November 30, 2009, proposed rule (74 FR 62521), HUD is seeking to eliminate FHA approval for loan correspondents. Because this rulemaking is still in process and a final rule has not yet been issued, FHA is extending the deadline for the submission of audited financial statements for loan correspondents seeking renewal of their FHA lender approval for 2010. For loan correspondents with a fiscal year end of December 31, and that would ordinarily be required to renew their FHA approval by March 31, 2010, HUD is providing these lenders with an additional 30 days in which to submit their audited financial statements. These loan correspondents must continue to comply with existing requirements for the submission of their Annual Certifications and renewal fees, but will be given until April 30, 2010, to submit audited financial statements. Again, the deadline for the submission of the Annual Certification and renewal fee has not been changed. Loan correspondents that do not complete their renewal in accordance with the deadlines as specified above will no longer be FHA-approved as of the effective date of the final rule that follows the November 30, 2009, proposed rule.
For years I have been warning anyone who would listen that, sooner or later, FHA would start cracking down on all the lenders out there flouting the rules and risking the safety of the FHA program. It seems our present mortgage crisis, along with some increased funding, may have finally triggered this crackdown. I couldn’t be more pleased. For a long time, bad lenders have been making the mortgage business hard for the originators who want to do things the right way.
FHA today announced some rather major guideline changes which will tighten up the availability of FHA loans. Your view regarding these changes is likely to be guided by your vantage point in the process.
Members of the general public who are not in the market for a home or a mortgage refinance will most likely approve. These changes certainly will improve the quality of the FHA loan pool moving forward. Provided, that is, the average FHA buyer can still meet the requirements.
WASHINGTON – U.S. Department of Housing and Urban Development (HUD) Inspector General Kenneth M. Donohue and Federal Housing Administration (FHA) Commissioner David H. Stevens announced today an initiative focusing on mortgage companies with significant claim rates against the Federal Housing Administration mortgage insurance program.