Addressing Continued Concerns About The FHA by Brian Montgomery

by 25 Nov 2009

“The reasons for FHA's problems are very different from the ones experienced in the subprime sector where unsafe loan features and poor underwriting made investing in non-agency mortgages risky from the start.”

In January of this year, both Joe Murin and I were asked by HUD Secretary Donovan to remain as Ginnie Mae president and FHA Commissioner respectively to help the new Administration deal with the on-going housing crisis. We both were privileged to be asked and were honored to continue serving in the Obama Administration for several more months.
However, today, as a former government official, if I could leave you with one message it would be this:
There has never been a point in our nation’s history that better illustrates exactly why FHA and Ginnie Mae exist. During these uncertain economic times, their counter-cyclical role of ensuring adequate mortgage activity and liquidity has been necessary and vital.
FHA has saved close to one million sub-prime/Alt-A borrowers from possible financial ruin by allowing them to refinance into a safe and secure 30-year fixed rate mortgage. Another 2 million qualified borrowers (80% of them first-time homebuyers) have taken advantage of the declining house prices and historically low interest rates to purchase a home using FHA.  FHA’s role has grown substantially from three percent of lending activity by dollar volume in 2006 to nearly twenty-five percent of all mortgages originated today. That massive uptick in volume occurred almost overnight beginning in spring 2008.
Through it all…. FHA has helped pump more than $400 billion of mortgage activity and liquidity into the market since 2008, while still managing to deliver a higher credit quality borrower whose average FICO score is 700.
One can only imagine how much worse our economy would be right now without the FHA. However, the growth of FHA in the past eighteen months has understandably attracted a lot of attention. While the FHA did not take part in the housing boom, it is feeling its effects.
As many anticipated, given the current sluggish economy, the FHA is experiencing an increased rate of delinquencies and more foreclosures.
Simultaneously, as home values fall or just fail to appreciate, the number of homes the FHA insures is rising significantly. In October, this forced HUD to announce that in 2010 the FHA's reserves could dip below the mandatory two percent level required by Congress. (Which was discussed in last month’s column)
Reminder: FHA collects premiums from borrowers (revenue) and also pays out claims to lenders when loans go into default and foreclosure (outlays). 
For FHA, the primary reason for continued defaults and foreclosures will be macro-economic problems that go beyond the scope of underwriting. For instance, continued job losses and the further decline of  home values and equity.
Absent a massive economic downturn, I don’t believe FHA will face the same type of catastrophic losses we saw in the subprime sector. The reasons for FHA's problems are very different from the ones experienced in the subprime sector where unsafe loan features and poor underwriting made investing in non-agency mortgages risky from the start.
The FHA has undeniably tightened guidelines in an effort to help ensure a higher loan quality. Prospective borrowers must verify income and job history as part of a rigorous underwriting process.
I offer this assurance in an effort to raise your comfort level as to the future of FHAFHA must keep its eyes on the ball to make certain that American homeowners and renters are served while American taxpayers are protected.
As a reminder, I offer the following insight about the strategies the FHA is considering to ensure the market remains confident in the FHA’s risk management models:
·        Tighten underwriting criteria
·        Increase premiums
·        Raise the down payment requirements above 3.5%
·        Overlay a credit score cut-off
Looking forward, it is important for all of us to continue advocating for reforms that better ensure a vibrant, transparent, and sound mortgage marketplace. Current market conditions highlight the critical role of the private and public sectors in keeping mortgage credit flowing.
All of us are trying to make sure we are well positioned to continue serving customers as this industry moves through truly tectonic change.  I welcome the opportunity to hear about the challenges you face and discuss how all of us are addressing this brave new world of mortgage finance.
As FHA Commissioner, Brian Montgomery was responsible for the oversight and modernization of the insurance fund’s $600 billion portfolio. He was also responsible for HUD's regulatory tasks to the housing mission of the GSEs and the manufactured housing industry. Montgomery came to HUD from the Executive Office of the President. At the White House, he contributed to the policy process on a wide range of issues including increase access to affordable housing.



Is TILA-RESPA a good or bad thing long term?