FHA To Borrowers: Gimme More!
The FHA has announced higher mortgage insurance premiums,stiffer downpayment standards for those with weak credit and more oversight for FHA-approved lenders.
What’s going on here? A few things:
First, FHA reserves are falling. The insurance program needs more money. What happens when insurance programs need cash? They raise premiums. In the case of the FHA they want to move from 1.75 percent up front to 2.25 percent.
Second, the FHA says if your credit score is below 580 you should not be among the annointed and allowed to borrow with just 3.5 percent down. Instead, borrowers with woeful credit will need 10 percent. The question, of course, is why the FHA does not offer 10% for investors.
Third, the FHA is concerned that owners are offering seller contributions which are forcing up home prices artificially. In other words, without a seller contribution — a credit to the buyer at closing of as much as 6 percent of the sale price — the sale price would actually be lower because the owner would not be trying to re-coup dollars being credited to the buyer. The FHA will limit seller contributions to 3 percent of the sale price, a common lender norm.
fourth, with the subprime market sunk, loan officers who once offered tasty toxic loans to unknowing borrowers now want to sell FHA mortgages. The FHA, with very good reason, wants to track lenders with far greater care than in the past given the influx of subprime loan officers and companies. In essence, if they break the rules even a bit the FHA is threatening to dump them.
The Details
Below is what the FHA says specifically:
1. Mortgage insurance premium (MIP) will be increased to build up capital reserves and bring back private lending
The first step will be to raise the up-front MIP by 50 bps to 2.25% and request legislative authority to increase the maximum annual MIP that the FHA can charge.
If this authority is granted, then the second step will be to shift some of the premium increase from the up-front MIP to the annual MIP.
This shift will allow for the capital reserves to increase with less impact to the consumer, because the annual MIP is paid over the life of the loan instead of at the time of closing
The initial up-front increase is included in a Mortgagee Letter to be released tomorrow, January 21st, and will go into effect in the spring.
2. Update the combination of FICO scores and down payments for new borrowers.
New borrowers will now be required to have a minimum FICO score of 580 to qualify for FHA’s 3.5% down payment program. New borrowers with less than a 580 FICO score will be required to put down at least 10%.
This allows the FHA to better balance its risk and continue to provide access for those borrowers who have historically performed well.
This change will be posted in the Federal Register in February and, after a notice and comment period, would go into effect in the early summer.
3. Reduce allowable seller concessions from 6% to 3%
The current level exposes the FHA to excess risk by creating incentives to inflate appraised value. This change will bring FHA into conformity with industry standards on seller concessions.
This change will be posted in the Federal Register in February, and after a notice and comment period, would go into effect in the early summer.
4. Increase enforcement on FHA lenders
Publicly report lender performance rankings to complement currently available Neighborhood Watch data – Will be available on the HUD website on February 1.
This is an operational change to make information more user-friendly and hold lenders more accountable; it does not require new regulatory action as Neighborhood Watch data is currently publicly available.
Enhance monitoring of lender performance and compliance with FHA guidelines and standards.
Implement Credit Watch termination through lender underwriting ID in addition to originating ID.
This change is included in a Mortgagee Letter to be released tomorrow, January 21st, and is effective immediately.
Implement statutory authority through regulation of section 256 of the National Housing Act to enforce indemnification provisions for lenders using delegated insuring process
Specifications of this change will be posted in March, and after a notice and comment period, would go into effect in early summer.
HUD is pursuing legislative authority to increase enforcement on FHA lenders. Specific authority includes:
Amendment of section 256 of the National Housing Act to apply indemnification provisions to all Direct Endorsement lenders. This would require all approved mortgagees to assume liability for all of the loans that they originate and underwrite
Legislative authority permitting HUD maximum flexibility to establish separate “areas” for purposes of review and termination under the Credit Watch initiative. This would provide authority to withdraw originating and underwriting approval for a lender nationwide on the basis of the performance of its regional branches
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