It looks like FHA Mortgage Insurance premiums will be changing once again, starting in September. The proposed changes will be voted on this month and will bring about an change in both up-front and monthly MIP.
Here is an excerpt from mortgage industry advocacy group IMMAAG:
"Almost two weeks before the closing of the public comment period on proposed FHA changes, Commissioner Stevens announced yesterday, August 5, 2010 the Congressional passage of HR5981 which allows FHA to increase the monthly insurance premiums on standard FHA programs up to 1.5%.
In applauding the congressional action, Mr. Stevens announced that effective with case numbers assigned beginning September 7, 2010 the front end MIP will be reduced 1.0% (100 basis points) which will reduce it 25 bps below last year's rate when it was increased from 1.50% to 2.25% while the monthly premiums will increase to 0.85% for borrowers with LTV's <=95% and to 0.90% for borrowers with loan amounts >95%.
As pointed out in a Loan Tool Box post yesterday by one of IMMAAG's subscribers (thank you Jason Klaskin - an MLO in PA) it is interesting that in the face of the Commissioner's cry to take steps necessary to as quickly as possible return the somewhat depleted Mutual Mortgage Insurance Fund (MMIF) to its statutory minimum level of 2.0% that the premium source generating the most immediate impact is reduced.
In what IMMAAGbelieves to be a further contradiction, we also wonder why, since the proposed rule goes to great lengths to establish the link between LTV and risk, that when FHA is proposing increasing down payment requirements for lower FICO borrowers that it would at the same time allow those who are "forced" to the lower LTV because of their risk profile to pay less on-going MI than those who by definition must have higher FICO's to qualify for the 95% LTV will pay a higher monthly premium. We continue to challenge the agency to explain some of the their responses to the analytical results they claim to have achieved.
Also, in the same vein, as we commented on with respect to the proposed Seller Contribution and Down Payment rule (Comments due 8/16/10) it seems contra-indicated, given the FHA "mission" to force those with the least amount of liquidity to further deplete the liquidity by putting more down in the purchase. It also follows that if they have less liquidity, they have a higher risk of failure when a negative life cycle event occurs, yet on an on-going basis beginning September 7, 2010 they will contribute less to the reserve pool than less risky, higher FICO borrowers. It is somewhat counter-intuitive to reduce the front end premium which can now be financed at extremely favorable rates in favor of higher monthly premiums which, by definition will increase debt service costs and will result in risk profiles that are worse than in today's environment.
Lastly, the bill itself requires the Commissioner to appear before both the Senate Banking Committee and the House Financial Services Committee within 270 days to "discuss the finances, including premiums, of the Federal Housing Administration." IMMAAG has to wonder, since Mr. Steven's testified on the overall FHA position as recently as October 2009 and since then he has announced several fundamental changes and proposed changes, how any discussion can provide useful empirical data about the effects of these continual modifications. Seems that in this short of a period, all the variables being changed by the FHA create a "moving target" that can't be hit, at least analytically.
IMMAAG solicits user comments on this and suggests that everyone consider including comments about this issue in responding to the open proposed changes. While this change does not directly address the proposed changes, it does have an impact on the overall objectives stated in FR-5404-N-01 (the docket number for the Seller Contribution proposal).
Copies of the announcement and the one page bull (HR5981) are posted on www.immaag.com"