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Recently, FHA Commissioner Carol Galante has been extolling the FHA’s efforts at underwriting reform and to shrink its competition with the private sector.
For example, with respect to loans greater than $625,500:
“The combination of a higher down payment and higher mortgage insurance premiums for these loans will continue our efforts to drive this business to the private market.”
And regarding minimum credit score for all new loans:
This will “reduce claim rates by approximately 20 percent for borrowers with credit scores of 620 or below… this policy change will significantly strengthen the extent to which… borrowers are offered loans that are sustainable for them.”
Is this reform or the illusion of reform?
Loans greater than $625,500:
1. FHA raised the premium 25 bps in June 2012 for loans over $625,500.
a. In CY 2012 a mere 0.5% of FHA’s volume was greater than $600,000 (note: FHA does not report for greater than $625,500, so this percentage would be even less). This compares to the same 0.5% in CY 2011.
b. Since the same infinitesimal number of FHA loans exceeded $625,500 in both 2011 or 2012 this claim of reform is illusory.
2. In November 2012 the FHA announced it would raise the premium for all loans, including loans above $625,500, by another 10 bps.
3. In January 2013, FHA announced, in an effort to “scale back FHA market share”, that it would lower the maximum LTV on loans greater than $625,500 from 96.5% to 95%. FHA Commissioner Galante said “The combination of a higher down payment and higher mortgage insurance premiums for these loans will continue our efforts to drive this business to the private market.”
Bottom line—these changes make great sound bites but this is merely the illusion of reform.
Minimum credit score for all new loans:
1. Borrowers with credit scores below 620 have to have a maximum debt-to-income (DTI) ratio no greater than 43% using automated underwriting with any exceptions requiring manual underwriting.
a. FHA Commissioner Galante said “this requirement would reduce claim rates by approaximately 20 percent for borrowers with credit scores of 620 or below… this policy change will significantly stengthen the extent to which… borrowers are offered loans that are sustainable for them.”
2. In FY Q.3:12, about 3% of FHA’s volume had a FICO score below 620 (down from 45% in 2007). This drop is almost entirely due to lender credit overlays, not actions taken by FHA. Thanks to lenders’ prudent actions, the FHA has avoided billions of dollars in additional losses. As gratitude, HUD has made noises about outlawing the practice of credit overlays.
a. These changes would only impact a tiny percentage of the FHA’s business, leaving large and risky swaths of its insurance business untouched.
3. Using a claims rate projection model based on an analysis of 3.4 million loans, FHA loans with a FICO below 620, an LTV of 96.5%, a 30-year term and a DTI range of 41-55% have an expected claim rate of 28.6% (characteristics before the announced change).* Limiting DTI to a max of 41% as proposed by FHA reduces the claim rate to 23.1%. True, this is a reduction of 19.2%, right on par with FHA’s estimate of a 20% decline, but loans with a 23% claim rate are not sustainable.
a. FHA has once again nibbled around the edges for headline effect.
4. The reality is that sustainable loans to borrowers with 580-619 FICOs can’t be done without a shorter loan term than 30 years and a higher down payment than 3.5%.
Once again, these changes make great sound bites but clearly this is the illusion of reform.
It will take real reform, not the illusion of reform, to end the nightmare at FHA.
* Based on a book of loans with an overall loan claim rate of 10%, slightly less than FHA’s 37 year average loan claim rate of 10.63%.
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