Tag Archives: FHA

Moving To Opportunity

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Mount Laurel

The Center on Budget and Policy Priorities has posted Realizing the Housing Voucher Program’s Potential to Enable Families to Move to Better Neighborhoods. It opens,

Housing Choice Vouchers help families afford decent, stable housing, avoid homelessness, and make ends meet. They also enable children to grow up in better neighborhoods and thereby enhance their chances of long-term health and success. When African American and Hispanic families use housing vouchers, for example, their children are nearly twice as likely as other poor minority children to grow up in low-poverty neighborhoods and somewhat less likely to grow up in extremely poor areas. Still, 280,000 children in families using vouchers lived in extremely poor neighborhoods in 2014. Vouchers could do much more to help these and other children grow up in safer, low-poverty neighborhoods with good schools.

Public housing agencies have flexibility under current Housing Choice Voucher (HCV) program rules to implement strategies to improve location outcomes, and state and local governments could facilitate these efforts. But without changes in federal policy to encourage state and local agencies to take such steps and to modify counter-productive policies — and reliable funding to maintain the number of families receiving HCV assistance and to administer the program effectively — there is little reason to expect better results.

Federal, state, and local agencies can make four sets of interrelated policy changes to help families in the HCV program live in better locations:

  • Create strong incentives for state and local housing agencies to achieve better location outcomes;
  • Modify policies that discourage families from living in lower-poverty communities;
  • Minimize jurisdictional barriers to families’ ability to live in high-opportunity communities; and
  • Assist families in using vouchers to rent in high-opportunity areas. (1)

This paper poses a number of concrete policy proposals for HUD to increase choices for voucher recipients. They include giving weight to location outcomes for recipients in measuring local housing agency performance; aligning these goals with the new fair housing rules; and providing incentive payments to local agencies that help voucher recipients move to higher-opportunity areas. (8) There are more concrete proposals in the paper that I leave to the reader to review.

What I like about these proposals is that many of them can be implemented administratively by HUD, just like the fair housing rules were. I hope HUD is giving this paper its full attention — there is a lot of good stuff in it that can help people move to opportunities that they cannot currently access.

Tuesday’s Regulatory & Legislative Round-Up

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FHA’s Clean Bill of Health

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HUD Secretary Castro

HUD Secretary Julián Castro

The Federal Housing Administration released its Annual Report to Congress on the Financial Status of the FHA Mutual Mortgage Insurance Fund. The MMIF covers the lion’s share of the FHA’s mortgage insurance obligations. In his forward to the report, HUD Secretary Castro focused on the achievement of two goals, the MMIF has “reached its congressionally mandated capital ratio” and it “reduced its annual mortgage insurance premium” which “opened the doors for tens of thousands of Americans to become homeowners or to refinance into a more affordable loan.” (2) Some commentators had been critical of lowering the premium before the MMIF reached its mandated capital ratio, but all’s well that ends well, or so it seems.

I was particularly struck by the key characteristics of FY 2015 FHA borrowers:

  • The average credit score for all FHA endorsements was 680, and the average loan size was $190,928 for all mortgages, and $186,176 for purchase mortgages.
  • 82 percent of FHA purchase loans (614,148 loans) were for first-time homebuyers.
  • In calendar year (CY) 2014, FHA provided financing for 43 percent of all African-American borrowers, and 44 percent of all Hispanic borrowers. In contrast, in CY 2014, FHA represented just 21 percent of the total purchase market.
  • African-American borrowers represented 10.4 percent of total FHA endorsements in FY 2015; Hispanic borrowers represented 17.4 percent of total FHA endorsements in the same period.
  • FHA assisted more than 57,990 senior households to age in place through the Home Equity Conversion Mortgage (HECM) [reverse mortgage] program.
  • At the state level, during CY 2014, FHA-insured loans represented at least 20 percent of all purchase activity in 32 states. In 12 states and Puerto Rico, FHA-insured lending represented a quarter of all 2014 purchase lending. Nevada, Puerto Rico, and Arizona had the highest proportion of FHA purchase activity in 2014, with FHA-insured loans representing 34 percent, 33 percent, and 31 percent of all purchase loans in those areas, respectively. Arizona and Nevada were particularly hard hit by the housing crisis, and FHA has played an important role in the recovery in those states. (6-7)

The FHA had an outsized role for the entire country after the financial crisis and it is still having an outsized role in many ways for many communities. The big issue going forward is whether the FHA will further lower its premiums in an attempt to reach more borrowers and if it can do so in a fiscally responsible manner.

Wednesday’s Academic Roundup

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Monday’s Adjudication Roundup

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CFPB Mortgage Market Rules

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woodleywonderworks

Law360 quoted me in Questions Remain Over CFPB Mortgage Rules’ Market Effects (behind a paywall). The story highlights the fact that the jury is still out on exactly what a mature, post-Dodd-Frank mortgage market will look like. As I blogged yesterday, it seems like the new regulatory regime is working, but we need more time to determine whether it is providing the optimal amount of sustainable credit to households of all income-levels. The story opens,

Despite fears that a set of Consumer Financial Protection Bureau mortgage rules that went into effect last year would cut off many black, Hispanic and other borrowers from the mortgage market, a recent government report showed that has not been the case.

Indeed, the numbers from the Federal Financial Institutions Examinations Council’s annual Home Mortgage Disclosure Act annual report showed that the percentage of black and Hispanic borrowers within the overall mortgage market actually ticked up in 2014, even as the percentage of loans those two communities got from government sources went down.

However, it may be too early to say how the CFPB’s ability-to-repay and qualified-mortgage rules are influencing decisions by lenders and potential borrowers as the housing market continues to recover from the 2008 financial crisis, experts say. 

“Clearly, there’s a story here, and clearly there’s a story from this 2014 data,” said David Reiss, a professor at Brooklyn Law School. “But I don’t know that it’s that QM and [ability to repay] work.”

The CFPB was tasked with writing rules to reshape the mortgage market and stop the subprime mortgage lending — including no-doc loans and other shoddy underwriting practices — that marked the period running up to the financial crisis.

Those rules included new ability-to-repay standards, governing the types of information lenders would have to collect to have a reasonable certainty that a borrower could repay, and the qualified mortgage standard, a class of mortgages with strict underwriting standards that would be considered the highest quality.

The rules took effect in 2014, after the CFPB made changes aimed at easing lenders’ worries over potential litigation by borrowers should their QMs falter.

Even with those changes, there were worries that black, Hispanic and low-income borrowers could be shut out of the market, as lenders focused only on making loans that met the QM standard or large loans, known as jumbo mortgages, issued primarily to the most affluent borrowers.

According to the HMDA report, that did not happen in the first year the rules were in effect.

Both black and Hispanic borrowers saw a small uptick in the percentage of overall mortgages issued in 2014.

Black borrowers made up 5.2 percent of the overall market in 2014 compared with 4.8 percent in 2013, when lenders were preparing to comply with the rule, and 5.1 percent in 2012, the report said. Latino borrowers made up 7.9 percent of the overall market in 2014 compared with 7.3 percent in 2013 and 7.7 percent in 2012, the federal statistics show.

And the percentage of the loans those borrowers got from government-backed sources like the Federal Housing Administration, a program run by the U.S. Department of Housing and Urban Development targeting first-time and low- to middle-income borrowers, the U.S. Department of Veterans Affairs and other agencies fell.

Overall, 68 percent of the loans issued to black borrowers came with that direct government support in 2014, down from 70.6 percent in 2013 and 77.2 percent in 2012, the HMDA report found. For Hispanic borrowers, 59.5 percent of the mortgages issued in 2014 had direct government support, down from 62.8 percent in 2013 and 70.7 percent in 2012.

For backers of the CFPB’s mortgage rules, those numbers came as a relief.

“We were definitely waiting with bated breath for this,” said Yana Miles, a policy counsel at the Center for Responsible Lending.

To supporters of the rules, the mortgage origination numbers reported by the federal government showed that black and Hispanic borrowers were not being shut out of the mortgage market.

“Not only did we not see lending from those groups go to zero, we’re seeing a very, very small baby step in the right direction,” Miles said. “We’re seeing opposite evidence as to what was predicted.”

And in some ways, the CFPB has written rules that met the goal of promoting safe lending following the poor practices of the housing bubble era while still giving space to lenders to get credit in the market.

“We have a functioning mortgage market,” Reiss said.

Mortgage Market, Hiding in Plain Sight

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David Jackmanson

I blogged about the Center for Responsible Lending’s take on the 2014 Home Mortgage Disclosure Act (HMDA) data yesterday.  The mere act of aggregating this data reveals so much about the state of the mortgage market. Today I am digging into it a bit on my own.

There is a lot of good stuff in the analysis of the HMDA data released by the Federal Financial Institutions Examination Council (FFIEC). I found the discussion of the effects of the Qualified Mortgage and Ability to Repay rules most interesting:

The HMDA data provide little indication that the new ATR and QM rules significantly curtailed mortgage credit availability in 2014 relative to 2013. For example, despite the QM rule that caps borrowers’ DTI ratio for many loans, the fraction of high-DTI loans does not appear to have declined in 2014 from 2013. However, as discussed in more detail later, there are significant challenges in determining the extent to which the new rules have influenced the mortgage market, and the results here do not necessarily rule out significant effects or the possibility that effects may arise in the future. (4)

This analysis is apparently reacting to those who have claimed that the new regulatory environment is restricting lending too much. The mortgage market is generally too complicated for simple assertions like “new regulations have restricted credit too heavily” or “not enough” There are so many relevant factors, such as changes in the interest rate environment, the unemployment rate and the change in the cost of housing, to be confident about the effect of the change in regulations, particularly over a short time span. But the FFIEC analysis seems to have it right that the new regs did not have such a great impact when they went into effect on January 1, 2014, given the similarities in the 2013 and 2014 data. This reflects well on the rule-writing process for the QM and ATR rules. Time will tell whether and how they will need to be tweaked.

While the discussion of the new rules was comforting, I found the discussion of FHA mortgages disturbing: “The higher-priced fraction of FHA home-purchase loans spiked from about 5 percent in early 2013 to about 40 percent after May 2013 and continued at monthly rates between 35 and 52 percent through 2014, for an annual average incidence of about 44 percent in 2014.” (15) Higher-priced first-lien loans are those with an APR that is at least one and a half percentage points higher than the average prime offer rate for loans of a similar type.

The FHA often provides the only route to homeownership for first-time, minority and lower-income homebuyers, but it must be monitored to make sure that it is insuring mortgages that homeowners can pay month in and month out. If FHA mortgages are not sustainable for the long run, they are likely to do homebuyers more harm than good.