Category: Uncategorized

Op-Ed: We must increase access to affordable mortgages for minority borrowers

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By: Lindsey Johnson


Homeownership has been on the rise over the past few years even during the COVID-19 pandemic, but a deeper look at who is able to become a homeowner reveals significant racial and economic gaps. With a growing recognition in Washington of this disparity and a renewed focus on increasing financial security for Black and Hispanic families, policymakers and industry have the opportunity to correct inequities and sustainably increase minority homeownership.

U.S. Census data for the third quarter of 2020 show that homeownership among White households stands at nearly 76 percent, compared to nearly 51 percent for Hispanic households, and 46 percent for Black households. Meanwhile, of the minority borrowers who qualified for home financing, many encountered added costs that make homeownership disproportionately more expensive or altogether out of reach.

COVID-19 has further compounded the racial and economic gap as millions of low- to moderate-income families have lost their jobs and face financial insecurity. The Urban Institute finds that Black and Hispanic homeowners are significantly more likely to face financial hardships and are more at risk of not being able to pay their rent or mortgage payment due to the impacts of the pandemic.

So, while we must focus on the pandemic and its impact on borrowers, and particularly minority borrowers, we must also not lose sight of addressing the longer-term systemic issues that unnecessarily increase costs or create barriers for minority borrowers. Importantly, expanding homeownership opportunities for minority borrowers does not have to be at the expense of the reforms made over the last decade that have drastically improved lending to protect consumers and avoid another housing market collapse. The housing finance system can remain stable and manage mortgage credit risk prudently, while also using data-driven, targeted approaches to reduce barriers to affordable mortgages for Black and Hispanic households.

Mortgage affordability could be further stressed once new regulatory mandates are implemented. This includes new capital requirements for Fannie Mae and Freddie Mac (the GSEs) recently finalized by the Federal Housing Finance Agency (FHFA). While it is essential that the GSEs hold appropriate capital, the rule must be balanced and policymakers should consider changes to elements of the final rule that threaten to raise the cost of mortgages for all borrowers and push homeownership farther out of reach for many families of color.

Additionally, policies that adversely drive up costs for minority borrowers should be re-examined and reduced or eliminated. Loan-level price adjustments (LLPAs) that were introduced by the GSEs in 2008 are especially burdensome for minority and first-time homebuyers. These fees are disproportionately paid by borrowers with lower down payments and credit scores, whose mortgages are already protected by private mortgage insurance. Essentially, borrowers are being double charged for the same risk protection. Industry and consumer advocates — including the National Fair Housing Alliance and the Center for Responsible Lending — have long urged the GSEs to reduce or eliminate these redundant fees.

Further, it is critical that policymakers recognize the role of low down payment mortgage options in facilitating homeownership. In fact, more than 80 percent of first-time homebuyers used low down payment mortgage options in the past several years — with options as low as 3 percent down. While these options have prudently enabled millions of people of all backgrounds to become homeowners, even more targeted down payment assistance programs should be considered for borrowers who may not have intergenerational wealth or equity from a previous home to contribute to a down payment. Legislation like Rep. Al Lawson’s (D-Fla.) First-Time Homeowners Assistance Act should be given close consideration when re-introduced in 2021. Meanwhile, President Biden has already expressed interest in a first-time homebuyer tax credit — a very welcome early signal from the new administration.

There are other issues that warrant attention, such as the low supply of affordable housing and lack of access to financial education. This list goes on, and we recommend that the Biden administration assemble a task force that includes broad representation from industry, consumer advocate community, and government to formulate an action plan, build consensus, and get to work.

As an industry that exists to help low- and middle-income households qualify for low down payment mortgages, private mortgage insurers understand the need to balance responsible lending with access to affordable mortgage finance credit. There are tangible and measurable steps to sustainably expand homeownership for minority families and fortunately there is an eagerness across the housing policy sector to achieve these outcomes.

This piece was first published in The Hill on January 30, 2021.

Letter: To Honorable Marcia Fudge, HUD Secretary Designate

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The Honorable Marcia Fudge
Secretary Designate
U.S. Department of Housing and Urban Development
451 7th Street SW
Washington, DC 20410

Dear Honorable Fudge,

U.S. Mortgage Insurers (“USMI”) and its member companies congratulate you on your nomination to serve as the Secretary of the U.S. Department of Housing and Urban Development (HUD). Your many years of public service, including as mayor of Warrensville Heights, Ohio and the U.S. Representative for Ohio’s 11th Congressional District, demonstrates your commitment to community, and will serve you well as Secretary of HUD, as you have no doubt seen in your own district the homeownership challenges facing hardworking American families.

For more than 60 years, the private mortgage insurance (MI) industry has enabled more than 33 million low- and-moderate income Americans to attain affordable and sustainable homeownership in the conventional market. Working with the government-sponsored enterprises (GSEs) —Fannie Mae and Freddie Mac— and lenders of all sizes and business models, private MIs help borrowers qualify for mortgage finance credit with down payments as low as three percent. In the past year alone, more than 1.5 million people were able to purchase or refinance their mortgage due to private MI. Nearly 60 percent of borrowers who purchased their home using private MI were first-time homebuyers and more than 40 percent had incomes of $75,000 or less. Importantly, because USMI members provide private capital in front of the GSEs and taxpayers, the industry also provides significant loss protection to the mortgage finance system, having covered well over $50 billion in claims through the 2008 financial crisis—losses that would have otherwise been borne by taxpayers.

Through the last year despite the unprecedented challenges presented by COVID-19 pandemic, mortgage credit has been largely affordable due to historically low interest rates and 2020 had the largest mortgage origination volume since 2006—both for the conventional and Federal Housing Administration (FHA) markets. Despite this record mortgage volume and historically low interest rates, there remain significant housing affordability challenges for many borrowers across the country, including that nationwide home price appreciation (HPA) has skyrocketed to 7.3 percent year-over-year, the highest increase since 2014. Moreover, for the past seven years, the segment of the market that has experienced the largest and fastest HPA has been the lower end of the market, which over the last year saw an increase of nearly 11 percent. A driving force behind the high HPA is the fact that consumer demand continues to outpace new home construction, thereby exacerbating housing affordability by driving up home prices and putting homeownership further out of reach for many prospective homebuyers, most notably for minority and first time borrowers.

Policy recommendations such as lowering FHA premiums too quickly and aggressively may significantly impact FHA’s ability to address the challenges that will arise as COVID forbearances end, and coupled with the high delinquencies for FHA loans, could ultimately lead to higher claims, potentially undermining FHA’s ability to help future borrowers. Further, reducing premiums would only add fuel to the fire in terms of artificially lowering what is already relatively affordable mortgage finance credit. Such actions would inject more “demand” into the market without addressing the “supply” side—which will only drive-up home prices further, hurting affordability at the lower end of the market most. Additionally, other policy recommendations such as ending FHA’s “life-of-loan” policy, which would require FHA to continue to insure loans (because FHA insurance does not in fact cancel) without coverage being paid for, could similarly weaken FHA and its ability to meet the housing needs of future borrowers, while also exposing taxpayers to undue risk. FHA’s insurance stays on the loan for the “life of the loan,” therefore those who suggest ending the “life of loan” premiums are essentially advocating for providing free government-backed insurance.

There are other areas that may represent barriers to homeownership that policymakers should also choose to explore, including the targeted use of down payment assistance (DPA) programs for the borrowers who are unable to attain even a 3 percent or 3.5 percent down payment, who truly need the support. It is important that DPA programs are structured and operated in a sustainable manner so as to not create excessive leverage and risk within the mortgage finance system, or pose undue risk to taxpayers and the economy, which will ultimately hurt vulnerable homeowners most. As federal policy makers look to increase homeownership, it is essential that it is done in a manner that promotes sustainable homeownership for borrowers, as it does more harm to a family to get into a home that they can then not afford. There are meaningful ways to enhance borrower sustainability, such as by using part of a DPA to establish a reserve account for certain borrowers. Reserve accounts have been proven to be predictive of a borrower’s ability-to-repay their loan, and by focusing on reserve accounts, HUD not only prioritizes getting people into homes, but also helping them be successful homeowners. There are other important considerations to promote sustainable homeownership, such as housing counseling, for borrowers where HUD or FHA aim to expand access to mortgage finance credit.

Finally, USMI’s members intimately understand the importance of ensuring access to affordable, prudent low down payment mortgages in the marketplace. Understanding that more than 80 percent of first-time homebuyers over the last several years have depended on access to low down payment lending, it is more important than ever that the government-backed FHA program and the conventional market backed by private MI operate in a consistent and coordinated manner. Each plays an important, and distinct, role in the housing finance system and they should not be competing for market share—a situation which ultimately does a disservice to the borrowers we serve and to taxpayers.

FHA has long been a vital resource for many borrowers who may not have the ability to attain mortgage finance credit through the conventional market. Our industry looks forward to working with you and welcomes the opportunity to further engage with HUD and FHA to identify and address risks in the system and barriers to homeownership for borrowers, as well as find ways to further enhance a coordinated and consistent housing market that provides for the greatest access to sustainable mortgage finance credit.

We wish you the best in your transition to HUD Secretary and look forward to working with you once you are confirmed.

Sincerely,

Lindsey D. Johnson
President

For a full PDF of this letter, click here.

 

Statement: Federal Housing Administration FY 2020 Annual Report to Congress

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WASHINGTON— Lindsey Johnson, President of the U.S. Mortgage Insurers (USMI), released the following statement on the Federal Housing Administration’s (FHA) release of its Fiscal Year 2020 Annual Report to Congress on the financial status of the Mutual Mortgage Insurance Fund (MMIF):

“Today’s report shows that the MMIF’s combined capital ratio stands at 6.10 percent, up from 4.84 percent last year, well above the statutory requirement of 2 percent. We applaud the FHA’s steadfast commitment to improving the fiscal health of the fund especially during these challenging times. The FHA continues to play an important role in the housing finance system, and we commend its ongoing collaboration with industry efforts to stabilize the market amidst the COVID-19 pandemic.

“The FHA is a vital part of the housing finance system and it must continue to focus on enhancing its financial strength to best serve the borrowers who need it the most. This is especially important for the FHA in a post-pandemic environment to ensure the agency does not unnecessarily expose taxpayers to undue mortgage credit risk. While some have called for the FHA to reduce its mortgage insurance premiums, the report makes it clear that this is unnecessary and imprudent at this time as consumers continue to have access to low cost mortgage credit. A reduction would diminish the MMIF’s ability to withstand potential stress caused by the economic fallout from the pandemic, evidenced in the nearly 11.6 percent of FHA-insured mortgages that are classified as seriously delinquent. Further, calls to end the premiums for the life of FHA loans are just a veiled way of reducing premiums. Such a move would jeopardize FHA’s ability to serve the borrowers who rely on its insurance today, and borrowers in the future who may need FHA to access homeownership. Now, more than ever, is the time for the FHA to sustain its financial health and focus on its core mission — to serve borrowers the conventional market is unable to adequately serve.

“USMI and our member companies look forward to continuing to work with FHA and Congress to foster a robust housing finance system that meets the needs of low down payment borrowers while protecting taxpayers. To this end, it is essential that federal policymakers advance a coordinated housing policy to best balance consumers’ access to affordable mortgage finance and prudent management of mortgage credit risk.”

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

Strength of MI Report

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USMI’s report, “Private Mortgage Insurance: Stronger and More Resilient,” highlights the many regulatory and industry-led reforms taken over the last decade to improve and strengthen the role of private mortgage insurance (MI) in the nation’s housing finance system. The report analyzes the various regulatory enhancements and the industry-led initiatives that private MIs have taken and continue to take to ensure sustainable mortgage credit through all market cycles and to better serve low down payment borrowers in the conventional market, especially during critical economic times. Click below to read the report.

The report also highlights the steps the industry has taken since the beginning of the COVID-19 pandemic to support the federal government foreclosure prevention programs, including the announcements made by Fannie Mae and Freddie Mac regarding forbearance programs and other mortgage relief available to support borrowers impacted by COVID-19.  USMI members have focused their efforts on helping borrowers remain in their homes by supporting their lender customers during these challenging times.

Among the enhancements to the industry in the last several years, the report outlines and analyzes the following:

  • Private Mortgage Insurer Eligibility Requirements (PMIERs) – Adopted in 2015 and updated in 2018 and 2020, PMIERs nearly doubled the amount of capital each mortgage insurer is required to hold. USMI members collectively hold more than $5.1 billion in excess of these requirements.
  • New Master Policy – Updated terms and conditions from mortgage insurers for lenders, which provide lenders with greater clarity pertaining to coverage.
  • Rescission Relief Principles – First published in 2013 and updated in 2017, these principles allow MIs to offer day-one certainty to lenders of coverage, including automatic relief after 36 timely payments.
  • MI Credit Risk Transfer (MI-CRT) Structures – Private MI companies have transferred $41.4 billion in risk on over $1.8 trillion of insurance- in-force (IIF) since 2015—through both reinsurance and insurance-linked notes.

Download the full report here.

Op-Ed: Low Down Payments Backed by Mortgage Insurance More Important Than Ever

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By: Lindsey Johnson

Today, the place you call home matters more than ever. Unfortunately, many Americans continue to believe homeownership is out of reach because they think a 20 percent down payment is needed to qualify for a mortgage.

A recent report by the private mortgage insurance (MI) industry finds that it could take a family earning the national median income over 20 years to save for a 20 percent down payment. But the wait decreases by 67 percent when a five percent down payment is the goal. Fortunately, millions of homebuyers each year qualify for home financing with low down payments.

Given the current economic environment due to COVID-19 and the desire of many people to keep more cash on-hand, low down payment loans are more important than ever. Low down payment mortgages with private mortgage insurance have proven to be a time-tested means for Americans to access affordable homeownership sooner while still providing credit risk protection and stability to the U.S. housing system. It is no wonder why more than 33 million homeowners have used this type of home financing and why its use is on the rise.

The report finds that in 2019, the number of low down payment loans backed by private MI increased 22.9 percent. Over 1.3 million home loans were purchased or refinanced with private MI, up from just over 1 million in 2018. Nearly 60 percent of the borrowers of these loans were first-time homebuyers and 40 percent had annual incomes of less than $75,000.

Why have millions turned to this type home financing?

Let us first take a closer look at a borrower who earns the national median income of $63,179. To save 20 percent, plus closing costs, for a $274,600 home, the median sales price for a single-family home last year, they would need to bring more than $63,000 in cash to the table. It could take up to 21 years to save up this amount based on the national savings rate dedicated towards a mortgage. But if this borrower qualifies using private MI on a five percent down payment mortgage, their wait time drops to just seven years. This type of home financing offers Americans a chance to secure home financing much sooner than previously believed.

Why is 20% the “magic number”?

Data demonstrates that borrowers who make larger down payments are less likely to default on their mortgages than borrowers with lower down payments. Therefore, lenders traditionally require a 20 percent down payment to offer mortgage financing to a borrower. This is where mortgage insurance steps in, providing credit enhancement for the borrower with a lower down payment, and insuring the loan for the lender in the event the borrower stops making their payments. Once the borrower builds 20 percent equity in their mortgage, the insurance can be cancelled, thus lowering the monthly payment. Private MI also helps Americans buy a home without necessarily breaking the bank.

Private mortgage insurance is offered on so-called conventional loans that are backed by the government sponsored enterprises (GSEs), Fannie Mae and Freddie Mac. When there is private MI on a loan, the risk protection provided to lenders for making a low down payment mortgage possible is extended to the GSEs too. In the event of a default, the private mortgage insurance stands to cover losses first, meaning private MI also protects taxpayers.

Supporting the American Dream

As the report demonstrates, private mortgage insurers’ role in the low down payment market significantly increased over the last five years. Between 2015 and 2019, private mortgage insurers’ market share in the low down payment lending sector increased from 34.8 percent of the insured market in 2015 to 44.7 percent in 2019, helping millions of Americans qualify for home financing.

Private MI offers a reliable path to the American dream of owning a home. Since 1957, private MI has helped more than 33 million Americans become homeowners while protecting taxpayers. And right now, more than ever, we are even more aware of the benefits of owning a home—from building wealth to creating stability to the importance of having a safe place to call your own.

Lindsey Johnson is the president of the U.S. Mortgage Insurers (USMI), the association representing the nation’s leading private mortgage insurance companies.

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Mortgage Professional America originally published USMI President Lindsey Johnson’s opinion piece, “Low down payments backed by mortgage insurance more important than ever” on August 10, 2020. 

USMI Member Reports

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Below are reports that outline data USMI is watching that will directly or indirectly impact housing and the MI industry. Data is mainly focused on employment, mortgage forbearance and access to credit.

Newsletter: February 2020

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We are ready for March Madness but will take the extra day in February to highlight what has been a very busy start to 2020 for housing policy!

CFPB Director on Qualified Mortgage (QM) Rule
Industry and Consumer Groups Call for Maintaining Prudent Underwriting Guardrails as Part of QM Patch Replacement
CFPB Director Kathy Kraninger Testifies before House Financial Services Committee
USMI Speaks on QM “in a Post-Patch World”
USMI President Lindsey Johnson at Structured Finance Association
FHFA Moves Ahead with Plans to End Conservatorship
FHFA Issues and RFI on FHLBank Membership
Administration and Congress Take Action on Housing Affordability
Dana Wade Nominated as FHA Commissioner
USMI President Lindsey Johnson on the FHA Insurance Fund
ICYMI: Extension of the MI Tax Deduction

 

  • Consumer Financial Protection Bureau (CFPB) Director on QM Rule. On January 17, CFPB Director Kathy Kraninger sent a letter to select members of Congress notifying them of the CFPB’s intentions to eliminate the debt-to-income (DTI) ratio requirement and move to a standard based on an alternative metric, specifically a pricing threshold. She wrote that the CFPB would extend the QM definition “for a short period until the effective date of the proposed alternative or until one or more of the GSEs [government sponsored enterprises] exits conservatorship, whichever comes first.” As for the DTI requirement, Director Kraninger proposed replacing it for a pricing threshold, such as the difference between the loan’s annual percentage rate (APR) and the average prime offer rate (APOR) for a comparable transaction (the APOR-approach).
  • Industry and Consumer Groups Call for Maintaining Prudent Underwriting Guardrails as Part of QM Patch Replacement. In response, on January 21, USMI joined eight other organizations on a letter to Director Kraninger recommending the CFPB replace the current QM definition with one that relies on measurable underwriting thresholds and the use of compensating factors (such as liquid reserves, limited payment shock, and/or a larger down payment from the borrower’s own funds) for higher risk mortgages (those loans with DTI ratios above 45 and up to 50 percent). This letter goes on to explain how alternative recommendations (e.g., using pricing thresholds) would have a negative impact on minority and lower income borrowers and should be avoided through the better approach of relying on other compensating factors that enable prudent underwriting and affordable access to credit.

    The organizations also urged “that the transition period from the existing GSE Patch to the new QM framework be sufficiently long to allow market participants adequate time to plan for, and adjust to, new rules and underwriting standards” in order to avoid the risks of regulatory uncertainty “that might cause mortgage originators to retreat from lending to creditworthy homebuying and refinancing borrowers.”
  • Kraninger Testifies before House Financial Services Committee. On February 6, Director Kraninger testified before the House Committee on Financial Services where the discussion on the QM definition continued. Representatives Nydia M. Velasquez (D-NY), Brad Sherman (D-CA), French Hill (R-AR), Warren Davidson (R-OH), Alma Adams (D-NC), and Anthony Gonzalez (R-OH) all raised questions on the CFPB’s plan to replace the DTI requirement and its potential impact on the housing finance market and on low-to-moderate income borrowers’ access to safe and affordable mortgage finance credit. When asked on the timing for the release of the QM Notice of Proposed Rulemaking (NPR), Director Kraninger responded “no later than May,” which was affirmed this week by the Bureau when it formally announced it will issue proposed changes to the QM definition by May. Director Kraninger said, “[t]he bureau will propose an alternative, such as a pricing threshold, to better ensure that responsible, affordable mortgage credit remains available to consumers.” If you have not read it yet, USMI released a blog last year with observations and recommendations for replacing the QM and balancing prudent underwriting with borrower access to affordable mortgage finance in the conventional market.
  • USMI Speaks on QM “in a Post-Patch World.” On February 18, USMI President Johnson spoke at a panel co-hosted by the Mortgage Bankers Association (MBA) and Women in Housing Finance (WHF) on the future of QM after the expiration of the QM Patch. The panel discussed how the housing industry could change in the near future and the roles that other housing intuitions, like private mortgage insurance (MI), will play in supporting a vibrant housing industry. 
  • USMI President Lindsey Johnson at Structured Finance Association (SFA). This week, USMI President Johnson, along with Pete Carroll from Core Logic, Andrew Davidson from Andrew Davidson & Co., Rajiv Kamilla from Goldman Sachs, Larry Platt from Mayer Brown, and Jeremy Switzer from Penny Mac, spoke on a panel at SFA’s conference in Las Vegas titled, “Building Industry Governance for the PLS Market.” Johnson discussed the important governance changes and enhancements in quality controls and industry practices and regulation that have occurred in the conventional market that would greatly benefit the private label security (PLS) market, including the underwriting criteria that have developed under the QM Patch. Johnson also spoke about the role private MI can play to bring greater credit quality assurances and ensure prudent risk management in the PLS market.
  • Federal Housing Finance Agency Moves Ahead with Plans to End Conservatorship. On February 3, FHFA awarded the investment bank Houlihan Lokey Inc. a potential $45 million advisory contract to help recapitalize the GSEs as part of the government’s plan to end their conservatorships. FHFA Director Mark Calabria stated “[h]iring a financial advisor is a significant milestone toward ending the conservatorships of the enterprises,” adding that “[t]he next major milestone for the FHFA is the re-proposal of the capital rule, which will happen in the near future.”
  • FHFA Issues a Request for Input (RFI) on Federal Home Loan Bank (FHLBank) Membership. Earlier this week, the FHFA issued a RFI for FHLBank membership, in which it seeks input “on whether the FHFA’s existing regulation on FHLBank membership ensures the FHLBank System, consistent with statutory requirements, remains safe and sound, provides liquidity for housing finance through the housing and business cycle, and supports the FHLBanks’ housing finance and community development mission.”
  • Administration and Congress Take Action on Housing Affordability. Yesterday, the FHFA announced the authorization of payments for 2019 from the GSEs to the Department of Housing and Urban Development (HUD) for the Housing Trust Fund and Treasury for the Capital Magnet Fund. The Housing Trust Fund, an affordable housing program designed to increase and preserve the supply of decent, safe, and sanitary affordable housing for extremely low- and very low-income households, received $326.4 million and the Capital Magnet Fund, a program focused on the developments, preservation, rehabilitation, and purchase of housing for low income families, received $175.8 million. Congress also took steps this week to explore housing affordability and the House Financial Services Committee marked up and approved four bills concerning housing and community development:
    • H.R. 5931, the “Improving FHA Support for Small Dollar Mortgages Act of 2020” (Clay-Stivers), would require FHA to conduct a review of its policies to identify barriers to supporting mortgages under $70k and report to Congress within one year with a plan for removing such barriers.  The bill was reported favorably to the House by a recorded vote of 48 to 0.
    • H.R. 149, the “Housing Fairness Act of 2020” (Rep. Green), would authorize increased funding for HUD’s Fair Housing Initiatives Program in addition to creating a new competitive matching grant program to support comprehensive studies of the causes and effects of ongoing discrimination and segregation, and the implementation of pilots to test solutions. The bill was reported favorably to the House by a recorded vote of 33 to 25.
    • H.R. 4351, the “Yes in My Backyard Act” (Rep. Heck), would require localities receiving CDBG funding to submit a plan to track and report on the implementation of certain land use policies that promote housing production. The bill was agreed to and reported favorably to House by a voice vote.
    • H.R. 5187, the “Housing Is Infrastructure Act” (Chairwoman Waters), would authorize $100.6 billion for investments in the nation’s affordable housing infrastructure, including public housing, supporting housing for seniors and people with disabilities, making housing affordable to the lowest-income people, and rural and Native American housing.  The bill was reported favorably to the House by a recorded vote of 33 to 25.
  • Dana Wade Nominated as Federal Housing Administration (FHA) Commissioner. On February 20, the White House announced President Trump’s intent to nominate Dana Wade as FHA Commissioner and oversee the agency’s $1.3 trillion portfolio. USMI President Lindsey Johnson issued a statement applauding the nomination, stating that USMI “look[s] forward to working closely with Dana Wade in seeking ways to establish a more complementary, collaborative, and consistent housing finance system that prudently enables homeownership for American families while also protecting taxpayers.”
  • USMI President Lindsey Johnson on the FHA Insurance Fund. Scotsman Guide shared USMI President Lindsey Johnson’s views on the current health of the FHA insurance fund in an article on the wider industry debate surrounding the FHA’s insurance fund. Johnson noted that the insurance fund is highly vulnerable to market changes, adding that “[t]axpayers are currently exposed to over $1.19 trillion in outstanding mortgage risk at the FHA. This would only increase if FHA insurance premiums were reduced. Also, any change to FHA’s life-of-loan coverage would mean exposing taxpayers to further undo risk.”
  • ICYMI: Extension of the MI Tax Deduction. In January, Congress passed the Further Consolidated Appropriations Act of 2020, which retroactively extended tax deductions for mortgage insurance premiums to calendar year 2018 and remains in effect throughout 2020. USMI President Lindsey Johnson issued a statement praising the extension saying, “[w]e are pleased Congress extended the mortgage insurance tax deduction for years 2018 through the end of 2020. Private MI has helped more than 30 million middle-income Americans become homeowners over the last 60 years, and for over 10 years the deductibility of mortgage insurance has helped benefit millions of these hard-working borrowers.” According to the most recent IRS statistics of income, in 2017 alone more than 2.285 million taxpayers benefited from the MI premium tax deduction. The deduction is available to homeowners (married filing jointly) with MI who have adjusted gross incomes under $100,000 and phases-out for adjusted gross incomes up to $110,000. Earlier this week, the IRS issued a news release (IR-2020-44) describing the procedure for taxpayers to claim benefits of for expired provisions for already-closed tax years. According to guidance from the IRS, homeowners seeking to retroactively claim a tax deduction for mortgage insurance premiums for tax year 2018 will need to file an amended return using form 1040-X.

Newsletter: November 2019

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CONGRATS TO THE NATS! While the baseball season has officially ended, housing finance reform still has a few innings left in the game. On Monday, National Mortgage News reported on U.S. Mortgage Insurers’ (USMI) release of new details on the growing mortgage insurance credit risk transfer (MI CRT) market. USMI President Lindsey Johnson also spoke about innovative MI CRT on a panel at the Structured Finance Association’s (SFA) Residential Finance Symposium. On the housing finance reform front, Federal Housing Finance Agency (FHFA) Director Mark Calabria said that he is currently in negotiations with the Treasury Department to amend the Preferred Stock Purchase Agreements (PSPAs). He also spoke at an event hosted by the American Action Forum (AAF), where he was followed by a panel discussion on housing finance reform. Last week, FHFA released its 2019 Strategic Plan and 2020 Scorecard for Fannie Mae and Freddie Mac (“the GSEs”). This comes following several recent comments by Director Calabria reiterating the agency’s commitment to responsibly ending the GSEs’ conservatorships. In mid-October, Citizens Against Government Waste (CAGW) applauded the direction of FHFA under Director Calabria’s leadership. Lastly, we’re seeing more movement coming with the nomination of Brian Montgomery as Deputy Secretary of the Department of Housing and Urban Development (HUD) in early October.

Despite a busy month, there’s still plenty to look forward to at the #NEXTDC19 conference on November 18 and 19, which will bring policy experts together and create a great stage for lively discussions on the future of housing policy. Most importantly, ahead of the Veterans Day holiday, we want to thank and recognize all of the veterans who have bravely served in the United States Armed Forces. We are grateful for your service. 

USMI announces details on MI Credit Risk Transfer. On November 4, USMI announced that private MI companies transferred nearly $34 billion in risk on nearly $1.3 trillion of insurance-in-force from 2015 to 2019 to the global reinsurance and capital markets. USMI released details on the development and growth of the MI CRT market, which outlines the types of structures being used by the industry to transfer risk to reduce volatility and exposure of mortgage credit risk within the mortgage finance system, including to the GSEs, and therefore taxpayers. It also finds that active adoption of CRT by private mortgage insurers has transformed the industry to better insulate it from cyclical mortgage markets and enhanced MIs’ ability to be more stable, long-term managers and distributors of credit risk.

USMI President Lindsey Johnson spoke to MI CRT on a panel at the SFA’s Residential Finance Symposium. She also spoke with National Mortgage News on the innovative ways private MI is now actively managing mortgage credit risk. Johnson stated that in recent years mortgage insurers are not just participating in GSE CRT transactions, but also distributing their own risk through MI CRT.

AAF hosts panel discussion on housing finance reform. On November 6, AAF hosted a panel titled, “Fannie Mae and Freddie Mac: What’s Next?” Speakers included FHFA Director Mark Calabria; Dr. Norbert Michel, Director of the Center for Data Analysis at the Heritage Foundation; Dr. Michael Stegman, Senior Fellow of the Housing Finance Program at the Milken Institute Center for Financial Markets; and Thomas Wade, Director of Financial Services Policy at AAF. The panel was moderated by CNN’s senior economics writer, Donna Borak. The panel discussed the Treasury Department’s and HUD’s GSE Reform Plans, FHFA’s and Treasury’s actions to allow for the recapitalization of the GSEs, and additional reform initiatives by the Administration.

FHFA releases new Strategic Plan and Scorecard for Fannie Mae and Freddie Mac. On October 28, FHFA released its 2019 Strategic Plan and 2020 Scorecard, detailing the near-term future for the GSEs. In the Strategic Plan, FHFA provided a roadmap on how the GSEs will fulfill their statutory missions and maintain their focus on safety and soundness while preparing for what the FHFA calls “a responsible end to the conservatorships.” The 2020 Scorecard details how the GSEs will remain accountable for “the effective implementation of the Strategic Plan in the coming year.” Both documents outlined three key goals: (1) foster competitive, liquid, efficient, and resilient (CLEAR) national housing finance markets that support sustainable homeownership and affordable rental housing; (2) operate in a safe and sound manner appropriate for entities in conservatorships; and (3) prepare for their eventual exit from conservatorships.

In FHFA’s press release, Director Calabria said, “Our nation’s mortgage finance system is in urgent need of reform. The vision for reform articulated in the Strategic Plan and advanced in the Scorecard will serve borrowers and renters by preserving mortgage credit availability, protect taxpayers by ensuring Fannie Mae and Freddie Mac can withstand an economic downturn, and support a strong and resilient secondary mortgage market.”

FHFA intensely focused on the GSEs exiting conservatorship. At a meeting with reporters on October 31, Director Calabria noted that he is not giving Fannie and Freddie an easy pass. “I’ll certainly say I have yet to meet anybody who wants to get out of conservatorship as much as Fannie and Freddie do. But certainly, what you’ve been seeing over the last few years is not the kind of day-to-day behavior that you would expect from companies that are in conservatorship.”

Earlier that week, Director Calabria gave a keynote speech at the Mortgage Bankers Association’s Annual Convention in Austin, TX, and explained that after just one quarter of capital retention where Fannie and Freddie profits weren’t swept to Treasury, the companies doubled their capital buffers. “Fannie and Freddie will move forward thoughtfully, but this does not mean moving slowly.” But as exiting the conservatorship moves closer, Director Calabria explained he will ensure that it is done right. “I will not end the conservatorship unless I am confident that once Fannie and Freddie leave, they will never have to return.”

CAGW applauds FHFA’s new leadership. On October 16, CAGW wrote that “Mark Calabria is moving FHFA in a new direction and making taxpayers his top priority.” CAGW provided several examples of Director Calabria’s work, including FHFA’s focus on building capital at the GSEs to protect taxpayers, revising the GSEs’ multifamily lending caps, and the termination of the GSEs’ Mortgage Servicing Rights (MSR) pilot program.  Regarding the MSR pilot, CAGW noted that FHFA should apply this logic to any other pilots that allow the GSEs to push into markets and engage in activities that are already thriving. It is promising that Director Calabria is reviewing all pilots and new activities that expand the GSEs’ market dominance and encourages the enterprises to expose taxpayers to additional risk.”

Nomination of Brian Montgomery as HUD Deputy Secretary. On October 8, HUD announced that Commissioner Montgomery had been nominated to serve as Deputy Secretary and the Senate Banking Committee will consider his nomination on November 20. Montgomery, who also serves as HUD’s Assistant Secretary for Housing and Federal Housing Commissioner, would manage the day-to-day operations of the agency and assist Secretary Carson in leading the department’s nearly 8,000 employees. USMI applauded the decision, noting “Commissioner Montgomery is a respected, seasoned mortgage finance expert, and his unique experience and past public service have been major assets to the FHA. His extensive background will allow him to immediately begin work on the most important issues facing the housing finance system.”

Upcoming events. The#NEXTDC19 conference is an event focused on delivering policy intel. On November 18 and 19, it will bring together the most influential housing policy leaders, mortgage lenders, and fintech firms.

Press Release: Private Mortgage Insurers Transfer Nearly $34 Billion in Risk on Nearly $1.3 Trillion of Insurance-in-Force from 2015-2019

Posted on by dcadmin

USMI releases details on the developments and growth of private mortgage insurance credit risk transfer

WASHINGTON — U.S. Mortgage Insurers (USMI) today announced that private mortgage insurance (MI) companies transferred nearly $34 billion in risk on nearly $1.3 trillion of insurance-in-force from 2015 to 2019. USMI released details on the developments and growth of the MI credit risk transfer (MI CRT) market, which outlines the types of structures being used by the industry to transfer risk to reduce volatility and exposure of mortgage credit risk within the mortgage finance system, including to the government sponsored-enterprises (GSEs), and therefore taxpayers. It also finds that active adoption of CRT by private mortgage insurers has transformed the industry to help better insulate it from the cyclical mortgage market and enhanced their ability to be more stable, long-term managers and distributors of risk.

“Through innovative new MI CRT structures, the industry is taking additional steps to enhance MI resiliency and the risk protection provided to the conventional mortgage market. MI CRT demonstrates that MI companies are sophisticated experts in pricing and actively managing mortgage credit risk,” said Lindsey Johnson, President of USMI. “Private MI plays a critical function in the housing finance system by serving as the first layer of protection against mortgage defaults. MI is also one of the only sources of private capital that has been available through all market cycles. After the financial crisis, the MI industry improved its safety and soundness through enhanced capital and operational standards, which in turn made us more resilient to withstand severe economic stress.”

USMI examined the two main MI CRT structures: Reinsurance and Capital Markets. It found that mortgage insurers have executed 18 reinsurance deals since 2015, transferring over $25 billion of risk on over $530 billion of insurance-in-force. As for the Capital Markets structure, the industry introduced MI Insurance Linked Note (ILN) programs beginning in 2015. Since then, mortgage insurers have issued 19 ILN deals, transferring $7.8 billion of risk on over $730 billion ofinsurance-in-force.

“While the MI industry has distributed credit risk for decades, these innovative CRT structures adopted by the industry in 2015 have transformed it from a ‘buy-and-hold’ into an ‘aggregate-manage-and-distribute’ model,” said Johnson. “The financial risk management approach of private MI companies has become much more countercyclical and significantly benefits the housing finance system.”

Because private mortgage insurers typically hold a portion of the first loss there is an alignment of incentives that ensures quality underwriting continues to be done by the industry, which reduces investors’ risk exposure, and ensures quality control on risk for investors and within the broader financial system. The investor base in these transactions continues to grow exponentially as the frequency of transactions increases, and the MI CRT investors to date represent trillions of dollars of private capital under management that provides a stable, deep pool of liquidity for the market.

“The MI CRT structures underscore the resilient nature and benefits of MI and the private capital it supplies to the housing market, safeguarding taxpayers against mortgage defaults, and ensuring that the private MI industry will continue to play a vital role in the mortgage finance system,” added Johnson.

More information on MI CRT is available here.


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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership.

Statement: Nomination of Brian Montgomery as Deputy Secretary of the HUD

Posted on by dcadmin

WASHINGTON — Lindsey Johnson, President of U.S. Mortgage Insurers (USMI), today issued the following statement on the President’s intent to nominate Federal Housing Administration (FHA) Commissioner Brian Montgomery as Deputy Secretary of the U.S. Department of Housing and Urban Development (HUD):

“USMI applauds the White House’s intent to nominate Brian Montgomery to serve as the Deputy Secretary of HUD. Commissioner Montgomery is a respected, seasoned mortgage finance expert, and his unique experience and past public service have been major assets to the FHA. His extensive background will allow him to immediately begin work on the most important issues facing the housing finance system. USMI and the private mortgage insurance industry look forward to working with Commissioner Montgomery going forward to establish a coordinated and robust housing finance system that prudently enables homeownership for American families.”

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

Newsletter: September 2019

Posted on by dcadmin

Congress is back from recess, Pumpkin Spice lattes are back on the menu, and housing finance reform is back at the top of news headlines in Washington this fall. In September, the Trump Administration released plans to reform the nation’s housing finance system. USMI issued a statement applauding the initiative and calling for Congress to address the GSEs’ underlying structural challenges and promote a coordinated federal housing policy. The Senate Banking Committee also held a hearing on the matter to learn more about the Administration’s Plans. The same week that the Administration released its Plans, the Fifth Circuit ruled in favor of GSE shareholders in their lawsuit against the U.S. Treasury, as the court allowed the shareholders to reinstate claims alleging that FHFA is unconstitutionally structured. While the fate of the legal challenges is still unclear, what is clear is that FHFA is moving ahead on many of its plans to review and make changes to the current programs and activities of the GSEs. Last week, FHFA announced an increase to the caps on the amount of multifamily loans the GSEs can purchase next year, and just this week FHFA announced an end to the GSEs’ pilots to offer lines of credits to non-bank servicers that pledge agency mortgage servicing rights (MSRs) as collateral. Additionally, the CFPB closed its comment period on its Advance Notice of Proposed Rulemaking (ANPR) this week on the “Qualified Mortgage Definition under the Truth in Lending Act.” USMI submitted comments outlining several recommendations to the Bureau to balance prudent underwriting with consumers’ access to mortgage finance credit. Lastly, the House Financial Services Committee held a markup on several housing related bills, including legislation to reauthorize the HUD to implement credit scoring pilots in the underwriting process for FHA insured mortgages.

  • The Trump Administration’s Housing Finance Reform Plans. On September 6, the U.S. Treasury Department and the U.S. Department of Housing and Urban Development (HUD) released their comprehensive Housing Reform Plan and Housing Finance Reform Plan to end the federal conservatorships of the government sponsored enterprises (GSEs), which have lasted more than 11 years. USMI released a statement that applauds Treasury and HUD for their comprehensive plans and calls for Congress to address the underlying structural challenges of the GSEs. USMI wrote, “the Administration’s proposals to reduce taxpayer risk exposure and address the areas of misaligned incentives of the GSEs while increasing transparency and market discipline could be the catalyst to break the legislative logjam and enable policymakers to enact comprehensive reforms.” USMI also appreciates that Treasury and HUD identified specific areas where the Administration can focus its efforts to put the housing finance system on a more sustainable path. Many of the actions proposed by the Administration’s Plans align with USMI’s principles for Administrative Reform, including increasing transparency in the housing finance system and expanding the role of private capital ahead of taxpayer risk.
  • Senate Banking Committee Hearing. After the release of the Administration’s Plans, the U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing on September 10 titled “Housing Finance Reform: Next Steps,” in which HUD Secretary Ben Carson, Treasury Secretary Steve Mnuchin, and Federal Housing Finance Agency (FHFA) Director, Mark Calabria, delivered their testimonies and answered questions from committee members.

    All three Administration officials reiterated the need for Congress to provide input on reform, inviting the Legislative Branch to take a leadership role. Treasury Secretary Mnuchin said, “[p]ending legislation, Treasury will continue to support FHFA’s administrative actions to enhance the regulation of the GSEs, promote private sector competition, and satisfy the preconditions set forth in the plan for ending the GSEs’ conservatorships.” FHFA Director Mark Calabria also noted that “[the GSEs] have expanded with the economy recently yet maintained risk and capital levels that ensure they will fail in a downturn. This pro-cyclical pattern harms low-income borrowers, making it easier to buy homes beyond their means when the economy is strong and harder to keep those homes when the economy is weak.”

    Chairman Crapo (R-ID) said in his opening statement that “[m]any of the legislative recommendations in the Plans that were released are consistent with my outline to fix our housing finance system, including attracting private capital back into the market; protecting taxpayers against future bailouts; and promoting competition.” Ranking Member Brown (D-OH) summarized the foundational principles for reform around which housing stakeholders are coalescing and added that “[w]e need a housing system built on a mission to serve borrowers and renters, no matter who they are, what kind of work they do, or where they live. That means we need policies that focus on increasing service for underserved markets, like rural areas and manufactured homeowners, and borrowers who have been locked out of the housing market over decades of discrimination.”

  • Fifth Circuit rules on FHFA. On September 9, the Fifth Circuit ruled in favor of investors suing the U.S. Treasury Department, allowing them to proceed with previously dismissed claims alleging the FHFA exceeded its authority with “net worth sweep.” “Congress created FHFA amid a dire financial calamity, but expedience does not license omnipotence,” U.S. Circuit Judge Don R. Willett wrote for a nine-member majority. “The shareholders plausibly allege that the Third Amendment exceeded FHFA’s conservator powers by transferring Fannie and Freddie’s future value to a single shareholder, Treasury.” The case will now be discussed in a Texas federal court where it was originally filed in 2016. The court will decide whether the restored investor claims should go to trial or be resolved on summary judgement.
     
  • FHFA increases GSEs multifamily lending caps and ends GSE MSR Pilot Program. On September 16, the FHFA increased caps on the amount of multifamily loans the GSEs can purchase next year. FHFA will now limit Fannie Mae and Freddie Mac to purchasing over $100 billion each -up from $35 billion each in the years 2018 and 2019- in multifamily-housing residential loans, between the fourth quarters of 2019 and 2020. FHFA also made other revisions to how the GSEs can conduct their multifamily businesses, now requiring that the two firms must have over one-third (37.5 percent) of their multifamily activities directed toward affordable housing. Furthermore, the new lending caps eliminate exclusions that allowed the GSEs to purchase loans in excess of the limits previously in place.

    “Multifamily housing is a critical component of addressing our nation’s shortage of affordable housing,” said FHFA Director Mark Calabria. “These new multifamily caps eliminate loopholes, provide ample support for the market without crowding out private capital, and significantly increase affordable housing support over previous levels. The Enterprises should also manage under the caps to provide consistent, stable liquidity to the market throughout the entire five-quarter period.” 

    Earlier this week, FHFA announced an end to the GSEs’ pilot program to finance MSRs. It was reported on May 7, that Freddie Mac had provided lines of credit for several nonbank servicers. In making the announcement, Director Calabria noted “[t]he MSR market is already served by a wide assortment of highly competitive private sources of capital and financing. Going forward, the Enterprises should focus on activities that are core to the guaranty business, mitigate risk, and are essential to end the conservatorships.”

  • CFPB closes comment period on QM definition. On September 16, the Consumer Financial Protection Bureau (CFPB) closed its comment period on its ANPR on the “Qualified Mortgage (QM) Definition under the Truth in Lending Act,” in light of the pending expiration of the provision commonly referred to as the “GSE Patch” in January 2021. USMI applauded the CFPB’s initiative of undertaking an assessment of this critical rule. It submitted a comment letter offering specific recommendations for replacing the current “GSE Patch” to establish a single transparent and consistent QM definition in a way to balance access to mortgage finance credit and proper underwriting guardrails to ensure consumers’ ability-to-repay (ATR). USMI’s recommendations include:

    • Maintaining the ATR and product restrictions as part of any updates to the QM definition to ensure discipline in the lending community and to protect consumers;
    • Retaining specific underwriting guardrails such as a debt-to-income (DTI) threshold but notes that DTI should not be a stand alone factor for ATR. Further, the USMI comment letter demonstrates through data that the DTI threshold should be adjusted to better serve consumers;
    • Because DTI should not be a stand along measure of ATR, USMI recommends developing a single set of transparent compensating factors for loans with DTIs above 45 and up to 50 percent for defining QM across all markets, similar to how the GSEs, FHA, and VA use compensating factors in their respective markets today.

      Importantly, nine Democratic U.S. Senators led by Senate Banking Ranking member Sherrod Brown sent a letter to the Bureau stating that as it considered amending the existing QM rule, the Bureau “must not undermine the elements of the rule that have made it effective: prohibitions on unsustainable product features and a verifiable demonstration at loan origination that the lender has evaluated the borrower’s ability to repay their loan.”

      Other associations and entities such as the National Association of Hispanic Real Estate Professionals (NAHREP), National Association of Home Builders, Digital Federal Credit Union, National Association of Federally-Insured Credit Unions (NAFCU), CNB Bank, International Bancshares Corporation, Wisconsin Credit Union League, Highlands Residential Mortgage, among others, share similar views as USMI that setting transparent compensating factors will help expand credit availability for many potential homeowners who may otherwise be left behind.

  • House Financial Services Committee Markup. On September 18-20, the U.S. House of Representatives Committee on Financial Services, held a markup hearing in which, along with several issues, they discussed H.R. 123, the “Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act,” and reported the legislation favorably to the House with a 32-22 vote. This bill would reauthorize the HUD statutory authority to implement a pilot program to increase credit access for borrowers with thin or no credit files through the use of additional credit data in the underwriting for FHA-insured mortgages.