Making it Easier to do Business with FHA: The New Single Family Housing Policy Handbook. DraA Applica(on through Endorsement secbon
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1 Making it Easier to do Business with FHA: The New Single Family Housing Policy Handbook DraA Applica(on through Endorsement secbon
2 Overview FHA is in the process of transforming its Single Family policy development processes, and our new FHA Single Family Housing Policy Handbook is a key component of this effort. As we con@nuously strive to improve our processes, we want through our mul@- phased SF Handbook effort to: Introduce you to our new Post, Publish, EffecBve rollout process Invite feedback Provide to implement policy changes 2
3 Purpose The purpose of this presentabon is to: Introduce the SF Handbook Discuss the recently posted drah of the Applica'on through Endorsement for Title II forward mortgages including: - Structure - Tips to navigate through the sec@on - Sugges@ons for reviewing the sec@on content - Sugges@ons for providing feedback using the feedback response worksheet 3
4 Handbook ObjecBves When completed, the new SF Handbook will: Serve as a single, authorita@ve source for FHA Single Family Housing policy Combine the content from numerous exis@ng handbooks, hundreds of Mortgagee LeNers, Housing No@ces and other sources of policy Use consistent, direct language, adop@ng commonly understood industry terms, where appropriate Provide a structure that follows the mortgage process Make is easier overall to do business with FHA 4
5 Handbook Approach To be developed in a mul@- phased approach: - Applica'on through Endorsement process for Title II forward mortgages is first phase posted online in drah format October 29 th. Feedback is voluntary and welcome though November 29 th. - Posted drah does not include: 203(k) Condominium Unit Mortgages Appraiser Requirements Some revisions may result in changes to our exis@ng policy for consistency and alignment, where appropriate, with industry prac@ces. 5
6 Future of the SF Handbook are currently in development. These include, but are not limited to: (k) Condominium Unit Mortgages Appraiser Requirements Servicing Reo/Claims Title I Home Equity Conversion Mortgages Eligibility Quality Assurance 6
7 NavigaBng through the Applica(on through Endorsement SecBon 7
8 How to Review this SecBon: Detailed Table of Contents levels for precision Follows flow of mortgage lifecycle with components through endorsement Document links to get from TOC and base requirements to special product/program sheets in separate Appendix Other appendices include Mortgage Insurance Premiums, Glossary of Terms and Glossary of Acronyms 8
9 Consider the following when planning your review: Review the Table of Contents to understand the framework of the drah Review the detailed requirements pages of the SF Handbook that cover: - Base processes for FHA s standard product (203(b)) from applica@on through endorsement. - FHA Total Scorecard and manual underwri@ng from start to finish. 9
10 Review the product/program sheets, defined in the Appendix. Review our other appendices that cover Mortgage Insurance Premiums, a Glossary of Terms and a Glossary of Acronyms. Base contains consistent formaang and, as appropriate: - Defini@on - Standard - Documenta@on Requirements - Other requirements or excep@ons as applicable 10
11 Product sheets in Appendix with special product/ program requirements 203(h) Mortgage Insurance for Disaster Back to Work Build on Your Own Land to Permanent Mortgages Energy Efficient Mortgages Manufactured Home Mortgages (Title II only) New Mortgages Refinances 247 Single Family Mortgage Insurance on Hawaiian Homelands 248 Mortgages on Indian Land 251 Adjustable Rate Mortgages Solar and Wind This drah does not include requirement for Condominium Units and 203(k) Mortgages products. FHA will publish these, as well as appraiser requirements, in the future. 11
12 12
13 Example B: A mortgagee is seeking informa@on on a Simple Refinance Mortgage: Step 1: Review our base requirements for Refinances. Step 2: Use the document link to access Simple Refinance product specific requirements in the product sheet located in the Appendix. Step 3: Review Simple Refinance product specific requirements in the product sheet. 1 2 Base Requirements: Review base requirements for Refinances Document Link: Document link within Refinance sec@on of document takes you from introduc@on to specific product requirements in product sheet IllustraBve Example: Simple Refinance Mortgage NOTE: FHA Simple Refinance Mortgage was previously called Credit Qualifying Refinance with Appraisal Mortgage 3 Product Sheet: Product sheet in Appendix has specific Simple Refinance requirements that are applied in addi@on to our base Refinance requirements 13
14 Highlights of DraA Policy Changes 14
15 Highlights of Policy Changes There are a number of policy and requirements changes in the drah Applica'on through Endorsement sec@on of the SF Handbook. A Highlights of Changes document has been developed and outlines some of the more significant policy and requirements changes. You are encouraged to review the Highlights of Changes document, as well as the en@re drah Applica'on through Endorsement sec@on posted on our DraHing Table web site at: hnp://portal.hud.gov/hudportal/hud?src=/program_offices/ housing/sp/sfh_policy_drahs 15
16 Global changes to the SF Handbook include: Format: standard (FHA standard), requirements, Outline FHA requirements to lenders: Changed references made to borrower to lender requirements to obtain or verify borrower Replaced judgment with more measures New Terminology: adopted some commonly understood industry terminology, such as adjusted value, base loan amount, and total loan amount Policy changes and alignment to certain industry best 16
17 Refinance Policy Changes The No Cash- out Refinance Mortgage previously consisted of only rate and term refinances. No Cash- out Refinance Mortgage products in the drah are organized in three subcategories: Rate and Term Simple Refinance (formerly Credit Qualifying Refinance with Appraisal Mortgage) Streamline Refinances 223(a)(7)) 17
18 Example of actual Streamline Refinance Mortgage Policy Changes Former Policy New Policy CLTV up to 125% Net Tangible Benefit Analysis: payment of 5% CLTV Unlimited Changed the of Net Tangible Benefit: Rate of 0.5% Added Term as a net benefit FHA is par@cularly interested in feedback on both the change to how a Net Tangible Benefit is measured (i.e., payment reduc@on to rate reduc@on,) and on the appropriate percentage for the rate reduc@on. 18
19 Eligibility Period for Borrowers with Prior Defaults and Claims on FHA Mortgages Allows borrowers to qualify despite prior claim payments if borrower complies with policy on period following default. Separates borrower eligibility requirements for delinquent Federal Debt (CAIVRS) from credit requirements for previous mortgage defaults. 19
20 Eligibility Period for Borrowers with Prior Defaults and Claims Former Policy New Policy If the borrower has had past delinquencies or previously defaulted on an FHA insured loan, the borrower must wait for three years before he/she is eligible for another FHA- insured mortgage. The three- year period begins when FHA pays the claim to the lender. This includes deed- in- lieu of foreclosure, as well as judicial and other forms of foreclosures. (Handbook A.2.g: Wai'ng Period for Borrowers With Past Delinquencies, Defaults or Claims on FHA Loans. If a borrower is currently delinquent on an FHA- insured mortgage, they are ineligible for insurance on a new FHA mortgage unless the delinquency is resolved. Other defaults and delinquencies are considered by the mortgagee when evalua@ng a borrower s credit. 20
21 CAIVRS: CAIVRS was originally designed as a credit repor@ng tool, but has since evolved into a tool for repor@ng both credit informa@on and informa@on on delinquent federal debt. FHA plans to eliminate the use of CAIVRS for credit considera@ons, making it easier for mortgagees to use CAIVRS to determine whether a borrower may have a delinquent federal debt. Former Policy Mortgagees must use CAIVRS to screen all borrowers (except those involved in a streamline refinance), including nonprofit agencies ac@ng as borrowers. The borrower is not eligible for Federally- related credit if CAIVRS indicates that he/she is presently delinquent on a Federal debt, or has had a claim paid within the previous three years on a loan made and insured on his/her behalf by HUD. New Policy Borrower Ineligibility due to Delinquent Federal Non- tax Debt Standard Mortgagees are prohibited from processing an applica@on for an FHA- insured loan for borrowers with delinquent federal non- tax debt, including deficiencies and other debt associated with past FHA loans. Mortgagees are required to determine whether the borrowers have delinquent federal non- tax debt. Mortgagees may obtain informa@on on delinquent federal debts from public records, credit reports or equivalent, and the Credit Alert Verifica@on Repor@ng System (CAIVRS) or an equivalent system. ResoluBon In order for a borrower with verified delinquent federal debt to become eligible, the borrower must resolve their federal non- tax debt in accordance with the Debt Collec@on Improvement Act. Only the creditor agency that is owed the debt can verify that the debt has been resolved in accordance with the Debt Collec@on Improvement Act. The mortgagee must verify that the creditor agency has resolved the debt by obtaining a clear CAIVRS report. The mortgagee may not rely solely on documenta@on of resolu@on provided by the borrower. 21
22 ApplicaBons and Disclosures: Aligns maximum age of loan documents to industry Former Policy Maximum Age of Loan ApplicaBon Documents At loan closing, all documents in the mortgage loan may be up to 120 days old, or 180 days old for new New Policy Maximum Age of Loan Application Documents Documents used in the origination and underwriting of a loan may not be more than 120 days old at the time of closing. Only documents whose validity for underwriting purposes is not affected by the passage of time, such as divorce decrees or tax returns, may be more than 120 days old at the time of closing. 22
23 RelocaBon: that a reasonable commu@ng distance is 100 miles. Former Policy RelocaBon: Primary Residence A borrower may be eligible to obtain another FHA- insured mortgage without being required to sell an exis@ng property covered by an FHA- insured mortgage if the borrower is reloca@ng, and establishing residency in an area outside reasonable commu@ng distance from his/her current principal residence. (Handbook B.2.d) RelocaBon: Secondary Residences Secondary residences are only permined when the appropriate HOC determines that an undue hardship exists, meaning that affordable rental housing that meets the needs of the family is not available for lease in the area or within reasonable commu@ng distance of work, and New Policy RelocaBon: Primary Residence A borrower may be eligible to obtain another FHA- insured mortgage without being required to sell an exis@ng property covered by an FHA- insured mortgage if the borrower is reloca@ng for an employment- related reason, and establishing a new principal residence in an area more than 100 miles from his/her current principal residence. RelocaBon: Secondary Residences the commu@ng distance to the borrower s workplace creates an undue hardship on the borrower and there is not available affordable rental housing mee@ng the borrower s needs within 100 miles of the borrower s workplace, and 23
24 Income UnderwriBng Policy Changes Explicitly states that and bonus income must have a one- year history; Allows use of commission income of less than one year and adds a calcula@on for commission income to align with industry best prac@ces; Adds a specific defini@on of salary and hourly for calcula@ng effec@ve income; Revises provisions related to employment length and history for self- employment income; Adds more specific guidance for trea@ng pension income versus IRA/401(k) to recognize the differing nature of these two income sources; Provides addi@onal requirements on rental income calcula@ons and documenta@on requirements subject to of ownership of each rental property; Adds a requirement for obtaining a bank statement or transac@on history to verify existence of trust income; Provides addi@onal specificity on required verifica@on and documenta@on for gih funds. 24
25 Deferred ObligaBons: Requires all debts to be included in monthly and provides a calcula@on for deferred obliga@ons, which conforms to industry best prac@ces. Former Policy Debt payments such as a student loan or balloon note scheduled to begin or come due within 12 months of the mortgage loan closing must be included by the mortgagee as anticipated monthly obligations during the underwriting analysis. Debt payments do not have to be classified as projected obligations if the borrower provides written evidence that the debt will be deferred to a period outside the 12- month timeframe. (Handbook C.6.a: Projected Obligations) New Policy vi- 1. Defini@on Deferred obligations refer to liabilities that have been incurred but where payment is deferred or has not yet commenced, including accounts in forbearance. vi- 2. Standard The mortgagee must verify and include deferred obligations in the calculation of the borrower s debt. vi- 3. Required Documenta@on The mortgagee must obtain written documentation of the deferral of the liability from the creditor and evidence of the outstanding balance and terms of the deferred liability. The mortgagee must obtain evidence of the anticipated monthly payment obligation, if available. vi- 4. Calcula@on of Monthly Obliga@on The mortgagee must use the actual monthly payment to be paid on a deferred liability, whenever available. If the actual monthly payment is not available for installment debt, the mortgagee must utilize the terms of the debt to establish the monthly payment. 25
26 Reviewing and Providing Feedback 26
27 FHA invites our stakeholders to review the drah Applica'on through Endorsement and provide feedback. To facilitate our review and analysis of your feedback, we have included a MicrosoH Excel feedback response worksheet for use in recording feedback. This feedback response worksheet is posted on our new Single Family Housing Policy DraHing Table web page at: hnp://portal.hud.gov/hudportal/hud?src=/program_offices/housing/sp/sfh_policy_drahs 27
28 Steps for Providing Feedback Go to our new DraHing Table web page at hnp://portal.hud.gov/hudportal/hud?src=/program_offices/housing/sp/ SFH_policy_draHs A feedback response worksheet is available for your use Feedback can be general or specific (i.e., by line and page number) Each stakeholder is asked to consolidate comments from your organiza@on into one submission. Submit feedback to SFHandbook@HUD.gov. Feedback period ends November 29,
29 Next Steps 1. Posted: DraH Applica'on through Endorsement of SF Handbook posted October 29, 2013 on FHA s DraHing Table at: hep://portal.hud.gov/hudportal/hud? src=/program_offices/housing/sj/ SFH_policy_draAs. Stakeholder feedback due by November 29, Publish: Finalized version of Applica'on through Endorsement sec@on will be posted on HUDClips.com, the official web resource for all Single Family policy, in early EffecBve: Requirements published in new sec@on will become effec@ve for mortgagees in mid- spring
30 Your feedback is important to us. THANK YOU!! 30
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