Comment Submitted by Tamara Ray

Document ID: HUD-2010-0063-0027
Document Type: Public Submission
Agency: Department Of Housing And Urban Development
Received Date: July 16 2010, at 12:00 AM Eastern Daylight Time
Date Posted: July 20 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: July 15 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: August 16 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b1a87b
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This is comment on Notice

FR–5404–N–01 Federal Housing Administration Risk Management Initiatives: Reduction of Seller Concessions and New Loan-to-Value and Credit Score Requirements

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I have been orginating FHA loans for 30 years and have seen many changes to the program in that time. It seems to me that when FHA was leading the industry in first time homebuyer lending and FNMA was following FHA's lead with regard to downpayment, concessions and underwriting the system worked. It wasn't until FHA started conforming to FNMA's lead on AUS, which I understand was sold to FHA by FNMA, that the system started to fail. When we were truly analyzing a credit report and employment history, rental history and ratio's with a manual underwrite and not allowing interested party DPA the system worked. Regulation has eliminated the seller funded DPA, increased the MIP to replenish the fund. Let's give the new regulation time to work and the housing market time to rebound and take another look then.

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Comment Submitted by Jeff Bell, Cobalt Mortgage
Public Submission Posted: 07/20/2010 ID: HUD-2010-0063-0002