WASHINGTON — Seth Appleton, President of U.S. Mortgage Insurers (USMI), the association representing the nation’s leading private mortgage insurance (MI) companies, issued the following statement on the release of the Federal Housing Administration’s (FHA) Fiscal Year 2025 Annual Report to Congress on the financial status of the Mutual Mortgage Insurance Fund (MMIF):
“FHA must remain well-capitalized in order to perform its critical countercyclical function in America’s housing market and enable access to mortgage credit for those who may not otherwise be able to secure financing through the conventional and portfolio mortgage markets that are backed by private capital. We commend HUD Secretary Scott Turner and FHA Commissioner Frank Cassidy for their prudent stewardship of the MMIF in 2025. While the MMIF Capital Ratio stands at 11.47% with Total Capital Resources for the forward program at 8.25%, USMI urges policymakers to continue the current disciplined approach to ensure the long-term health of the MMIF, while also considering modernized stress-based, loan-level risk-weighted standards for FHA similar to the frameworks applied to Fannie Mae and Freddie Mac (the GSEs) and the private MI industry in order to withstand times of severe economic stress.”
To increase transparency around the fiscal condition of the MMIF and FHA’s forward mortgage program and contextualize the numbers published in the Annual Report, USMI previously commissioned a third-party actuarial firm to estimate the risk-based capital FHA would be required to hold if subject to the same stress-based, loan-level risk-weighted capital frameworks as private mortgage insurers and the GSEs, as compared to FHA’s Total Capital Resources for the forward program stated in last year’s Annual Report to Congress.
If held to the same capital standard that private mortgage insurers must meet to insure loans acquired by the GSEs in the conventional market, the Private Mortgage Insurer Eligibility Requirements (PMIERs), it is estimated that FHA’s Total Capital Resources for the forward program, as of the end of FY2024, would run a $31.7 billion shortfall. Similarly, as of the end of FY2024, FHA would need to hold $50 billion more to meet the GSEs’ capital framework’s minimum requirement if applied to FHA’s book of business.
Read USMI’s full policy brief here to learn more about why policymakers should consider modernizing FHA’s Capital Ratio to ensure safety and soundness in the housing finance system.









