RE: Docket No. FR-5160-P-01
Acceptable Payment History for Late Request for Endorsement of
Mortgage For Insurance
DHI Mortgage Company respectfully submits comments regarding the Department
of Housing and Urban Development’s Proposed Rule on Acceptable Payment
History for Late Request for Endorsement of Mortgage for Insurance. The
Proposed Rule will require a six month payment history for loans submitted for
insurance more than 60 days after closing.
Delays other than a late payment may result in an endorsement submission
beyond 60 days after closing. For example, delays may be due to incomplete
information or missing documentation that is collected after closing. If the
proposed rule is passed, the Lender will be faced with uninsured loans for 6
months even if the borrower has made on-time payments but submitted late due
to other factors. In addition, investors are tightening guidelines and if lenders are
unable to insure government loans in a timely manner, loans may be subject to
repurchase. The Proposed Rule may steer companies away from providing FHA
financing in a time when product options are limited.
Concern for the increase in defaults and claims submitted to FHA may be
mitigated by recently passed legislation and revising current FHA guidelines such
as requiring pre- and post-funding homebuyer counseling. Homebuyer counseling
teaches borrowers the importance of homeownership and financial responsibility.
Counseling will benefit the borrower beyond the six months that is proposed in
this rule.
DHI Mortgage Company would like to thank HUD for the opportunity to comment
on the proposed rule.
Angela Hernandez
Secondary Marketing Operations Manager
DHI Mortgage Company
Comment Submitted by Angela Hernandez, DHI Mortgage Company
This is comment on Proposed Rule
FR-5160-P-01: Federal Housing Administration: Acceptable Payment History for Late Request for Endorsement of Mortgage for Insurance
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