Late
last week someone asked about HUD's Equal Access Rule. A month or so ago
Bankers Advisory released a notice regarding HUD's update to equal access rules
for marital status, gender identity and sexual orientation. HUD published the
notice on February 2nd in order to raise awareness of the HUD Equal
Access Rule requirements for actual or perceived discrimination. The final rule
was published on February 3rd, 2012 and changes to HUD's general
rule include expanding the definition of "family" to include "a
single person, who may be an elderly person, displaced person, disabled person,
near-elderly person or any other single person; or a group of persons residing
together, including family with or without children, elderly family,
near-elderly family, disabled family, displaced family and remaining members of
a tenant family." The term "gender identity" includes actual or
perceived gender-related characteristics and "sexual orientation"
means homosexuality, heterosexuality or bisexuality. The rule also revises
HUD's general program requirements by adding that ant recipient of HUD funds
may not "inquire about the sexual orientation or gender identity of an
applicant for, or occupant of, HUD assisted or HUD-insured housing for purposes
of determining eligibility. It is permissible to inquire into sex for
temporary, emergency shelter with shared sleeping areas or bathrooms, or to
determine the number of bedrooms to which a household may be entitled."
The Office of Single Family Housing has included the updates into its Single
Family Housing Policy Handbook, 4.0001, effective June 15, 2015.
The
February edition of the HUD Housing & FHA Monthly Review
has been published, which provides an overview of January mortgagee letters and
recent activity. Highlights from the report include mortgagee letter 15-01
implements the 50 bps reduction in FHA's MIP rates for most FHA Title II
mortgages and allows for cancellation of existing case numbers in order to
utilize the MIP rates found within the mortgagee letter. Mortgagee letter 15-02
provides policy guidance applicable to "ineligible" non-borrowing
HECM spouses that will not be eligible for the due and payable deferral period,
previously announced in mortgagee letter 2014-07. The requirements in ML 15-02
may be implemented for all HECM case numbers assigned on or after January 5, 2015.
In addition, on January 29th, the Multifamily Housing published a
memo providing guidance for Multifamily Property Assessed Clean
Energy (PACE) in California. The memo discusses prospective benefits
of PACE and clarifies information regarding the processes by which HUD insured
and assisted properties in California can receive assistance for energy and
water efficiency improvements within the program.
The
U.S. Department of Housing and Urban Development (HUD) and the U.S. Census
Bureau announced new residential construction
statistics for February 2015. Privately owned housing
units authorized by building permits in February were at a seasonally adjusted
annual rate of 1,092,000. This is 3 percent above the revised January rate of
1,060,000. Privately owned housing starts in February were at a seasonally
adjusted annual rate of 897,000. This is 17 percent below the revised January
estimate of 1,081,000. Privately owned housing completions in February were at
a seasonally adjusted annual rate of 850,000. This is 13.8 percent below the
revised January estimate of 986,000.
And as a reminder the Federal Housing
Administration (FHA) published additional sections of its Single Family Housing
Policy Handbook (SF Handbook; HUD Handbook 4000.1): including Doing Business
with FHA-Lenders and Mortgagees; Doing Business with FHA-Other Participants in
FHA Transactions - Appraisers, Quality Control, Oversight, and
Compliance-Lenders and Mortgagees; Quality Control, Oversight, and
Compliance-Other Participants in FHA Transactions - Appraisers, and Origination
through Post-Closing/Endorsement for Title II Forward Mortgages (Origination
through Endorsement) Appraiser, 203(k) and 203(k) Consultant Sections. The
March 18, 2015 SF
Handbookis now available on HUD's Client
Information Policy Systems (HUDCLIPS) web page.
Staying
on this vein, the FHA announced a web-based platform for mortgagee
submissions of FHA appraisal data and reports: Mortgagee Letter 2015-08, Electronic
Appraisal Delivery (EAD) Portal for FHA-Insured Single Family Mortgages. This
Mortgagee Letter announces FHA's implementation of its EAD portal, and provides
information about the portal and its mandatory use with FHA case numbers
assigned on and after June 27, 2016. The EAD portal will allow
transmissions to FHA of only those appraisals that comply with FHA's Single Family Housing Appraisal
Report and Data Delivery Guide. When submitting an appraisal,
the portal provides confirmation of a successful submission, or information
regarding required corrections that may need to be made before resubmitting and
transmitting to FHA. When an individual appraisal is submitted-whether
through the EAD portal or through the existing process until the mandatory
effective date-the appraisal submitted becomes the appraisal of record. FHA does
plan to incorporate the EAD portal into the Single Family Housing Policy
Handbook (SF Handbook; HUD Handbook 4000.1).
FHA Announced Electronic Appraisal Delivery
(EAD) Portal Implementation in its Mortgagee
Letter 2015-08. This information outlines details of the
portal and its mandatory use with FHA case numbers assigned on and after
June 27, 2016. "The EAD portal will make it easier to do business with
FHA by offering process and technology efficiencies that streamline appraisal
data transmission, promote quality up-front appraisal data, and reduce
post-endorsement appraisal data corrections."
SunWest announced it will be
removing the Automated Valuation Model (AVM) requirement on VA IRRRLs with
qualifying credit score equal to or greater than 580 for locks / commitments
made on or after September 16, 2014. For loans with the qualifying credit score
less than 580, a conventional appraisal (must be ordered through Sun West's
vendor order website) or an AVM, with specific requirements is required to
determine the LTV ratio.
A
while back we learned that new and Reduced Documentation Requirements for M&T-to-M&T FHA Streamline
Refinances
and enhancements to its FHA Streamline Refinance Program for existing M&T-serviced loans sold back to M&T are in affect starting last
month. Some key product highlights include: No Credit Report Required - a Risk-Based Pricing Disclosure from the Lender's standard credit
reporting vendor is required. Verification of Employment Not Required.
Verification of Income Not Required. IRS Form 4506 Required at Closing Only.
Another option to be added is an FHA Streamline Refinance with an Appraisal for
M&T-to-M&T transactions
only.
A
VA "Joint" loan is defined as a VA loan having any co-borrower other
than the veteran-borrower's married spouse. This could include (but is
not limited to) a veteran and girlfriend (not wife), a veteran and another
relative (i.e. two brothers), etc. The M&T Bank VA product page(s) has
been updated. Regarding flood insurance for FHA transactions, flood IS required
to cover any Non-Residential Detached Structure that has any part located in a
Special Flood Hazard Area (SFHA). This is required for FHA transactions
even though it is not a FEMA requirement and is required whether or not the
detached structure was given value by the appraiser.
Today analysts continue to cogitate on Friday's employment
number. The weaker-than-expected March jobs data adds to uncertainty about
the timing of fed funds interest rate lift-off. Some analysts have already
concluded that the weaker-than-expected March jobs data eliminates the
possibility of June lift-off but that fails to account for normal monthly
fluctuations in jobs data and ignores the fact that expectations were simply
too high. The March jobs report is the last one that the Fed will see before
the April 28/29 FOMC meeting but they will see three more weekly Initial
Jobless Claims reports. Many expect those reports to be strong so don't
eliminate the possibility of a June more in short term rates quite yet. The
probability of September lift-off has increased has increased. Janet Yellen has
repeatedly said that the timing of lift-off is data dependent - as if we need
to be reminded.
In a week like this where this
is no substantive scheduled economic news here in the U.S., the markets tend to
focus on a) overseas events, and b) minor news which ordinarily are of little
consequence. We do have a smattering of news, including the Fed's release of
its Minutes from the March 17-18 FOMC meeting, Initial Jobless Claims Thursday.
But that's about it. Rate sheets are roughly unchanged: we closed the 10-yr
at 1.84% and this morning we're at 1.84% with agency MBS prices about the same.
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