Very Important Changes to FHA Guidelines
Today, HUD Secretary Shaun Donovan, announced some very important changes to FHA guidelines that will be implemented as early as the first quarter in 2010.
Below is an excerpt from her testimony today. You can find the entire written testimony at: http://portal.hud.gov/portal/page/portal/HUD/press/testimonies/2009-12-02
An initial measure is to reduce the maximum permissible seller concession from its current 6 percent level to 3 percent, which is in line with industry norms, and we will continue to consider additional reductions. The current level exposes the FHA to excess risk by creating incentives to inflate appraised value.
Secondly, to protect the fund from the riskiest borrowers, we will for the time being also raise the minimum FICO score for new FHA borrowers.
We are currently analyzing what this floor should be, including the relationship between FICO scores and downpayments to determine whether we should increase FICO minimums in combination with changes to other underwriting criteria for lower downpayment loans.
Third, we have made the decision to exercise our authority to increase the up-front cash that a borrower has to bring to the table in an FHA-backed loan - to make sure that FHA borrowers have more "skin in the game" and a stronger equity position in their loans. There are several ways to accomplish this, and so we are currently analyzing various options to determine which is the most effective and consistent with our mission.
Finally, we are examining our mortgage insurance premium structure, to determine whether an increase is needed and, if so, whether it should be the up-front premium, the annual premium or both. Our current up-front premium of 1.75 percent is below the statutory cap of 3 percent, while the annual premium is currently at the statutory maximum. To protect against future uncertainty in market conditions, we are requesting authority from Congress to raise annual premiums, as this is one of the most effective means of raising capital for the fund with the least impact per borrower.
Indeed, while most of these changes I've just described we can make on our own with no additional authority-and we expect to provide detail and public guidance for these changes by the end of January-in some cases, we will need Congress' help. In addition to asking Congress to increase the current cap on the annual mortgage insurance premium for new borrowers, we are asking for additional authority for our proposals to hold all FHA lenders responsible for their fraud or misrepresentations by indemnifying the FHA fund. We will also be asking Congress to expand FHA's ability to hold lenders accountable nationally for their performance as I mentioned earlier.
Marianne Snygg, GRI, ABR, ASP
ERA Herman Group Real Estate
Colorado Springs and Monument Real Estate