← Mortgage Bankers Association
HUDRulemakingHUD-2010-0063

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

RIN
—
Last modified
Jan 7, 2021
Comment window
closed 5825d ago
Mortgage Bankers Association filings
2

Activity

Mortgage Bankers Association filed 2 comments on this docket between Aug 9, 2010 and Aug 16, 2010. 71 other organizations filed here. The comment window closed 5825d ago.

What Mortgage Bankers Association filed (2)

Aug 16, 2010· Comment Submitted by Andrew Szalay, Mortgage Bankers Association· HUD-2010-0063-0856

Filed on regulations.gov — full text not in the inline record.

View on regulations.gov →
Aug 9, 2010· Comment Submitted by Michelle Taylor, Gulf Coast Mortgage Bankers Association· HUD-2010-0063-0741

I have been in the mortgage business for over 30 years now. It is very difficult for Home Buyers to save the funds necessary to purchase a home with the current FHA minimum down payment of 3.5% (a recent increased from 3%). Even with seller contributions towards their closing costs of 6%. Still they may have to come up with at least $5,000. We used to see family members helping with the down payment as a gift in many cases, but families have less to contribute these days. I would think with all of the foreclosures and short sales available we would want to encourage home purchases and home ownership. We have already tightened credit and underwriting guidelines and we know that underwriting cannot protect against losses due to forclosures and short sales as a result of declining markets, economic downturns, job losses or other unforseen events. The highest cause of delinquencies and foreclosures or short sales have resulted from unforseen events (pregnancy, divorce, medical, job loss etc.) in the past. The difference is in past years home owners could sell their home in the event of a catastrophy or there was a nominal difference. The state of the economy in recent years has undermined that option leaving thousands of homes available and on the market with investor losses at unparalled heights. Increasing down payment requirements and furthur limiting seller contributions will only result in impeding what progress we are able to make with the FHA loan program in absorbing the excess housing we now have in this country. With housing at it's lowest levels and interest rates at theirs it would seem that increasing the level of qualified buyers at this time, not reducing it would be in everyone's interest. It is my professional opinion that maintaining the current levels of down payment requirements and seller contributions will not result in undue risk or increased delinquencies, forclosures or short sales for FHA financed properties. Thank you for your consideration.

View on regulations.gov →

Abstract

No abstract recorded.

View on regulations.gov →

Co-filers (71)

See everyone who commented →