On the recordMarch 10, 2011
This amendment came up in committee and failed during our committee markup by a vote of 33-22. The amendment removes all references to the mortgagee letter issued by HUD concerning the FHA Refinance Program, and I think that this announcement was the defining document for the program and provided guidance to lenders on the FHA Refinance Program. I think our concern is that the amendment leaves the door open for the Treasury and for HUD to at a later date create another substantially similar program to the FHA Refinance Program, again, without the express consent of Congress. As the sponsor of the bill mentioned, this program was never authorized by Congress. The funding came from the TARP moneys that were set aside for the HAMP program, and the mortgagee letter was effectively the authorizing document for the program. If this were to be in, there would be no nullification of the program; it wouldn't be terminated. This mortgagee letter speaks directly to this program, and I don't think that it affects the other parts of the FHA. It really just voids the letter, in doing so, to end the program. We don't need to further burden the FHA with this program. An FHA program right now is currently operating below its congressionally mandated 2 percent capital reserve ratio, and this program has the potential to further expose taxpayers to FHA losses. Even the administration has expressed concerns over the new program loan performance.





