CBCMA and FHA share a mission to expand homeownership opportunities for first time homebuyers and other borrowers who would not otherwise qualify for conventional mortgages on affordable terms, as well as for those who live in underserved areas where mortgages may be harder to obtain.
If you received assistance through the Program as a borrower, what circumstances or challenges did the Program assist you to overcome?
To what extent does the Program assist borrowers who could not receive assistance from any other source?
To industry professionals, how does the Program compare to other down payment assistance programs with respect to borrower accessibility, borrower qualifications, underwriting standards, and ease of use?
Have you encountered any regulatory impediments that have made the Program less effective or viable? If so, what are they and how would you suggest they be addressed?
As an Affiliate Member of the National Council of State Housing Agencies (“NCSHA”), CBCMA shares its national housing policy priority to preserve and strengthen its partnership with FHA with respect to down payment assistance.
Do you agree with the Program as a matter of housing policy? Please state your reasons why or why not.
Do you have any suggested Program changes that would bring the Program more into alignment with your housing policy positions? If so, what are they?
Do you think the Program is necessary or essential? Please state your reasons why or why not.
FHA insures mortgages through its Mutual Mortgage Insurance Fund (“MMIF”). The MMIF is a revolving fund that uses the proceeds from insurance premiums, investment income and foreclosure sales to provide funds for future mortgage insurance. Generally, FHA rules, regulations and guidelines (e.g. HUD Single Family Policy Handbook 4000.1) are promulgated to balance undue risks to the MMIF against FHA’s mission to expand homeownership opportunities for first time homebuyers and other borrowers who would not otherwise qualify for conventional mortgage on affordable terms, as well as for those who live in underserved areas where mortgages may be harder to obtain.
Are you aware of any practices or procedures undertaken by CBCMA that you believe pose undue risk to the MMIF?
Are you aware of any practices or procedures untaken by CBCMA that you believe are inconsistent with or not compliant with FHA rules, regulations or guidelines, (e.g. HUD Single Family Policy Handbook 4000.1?).
Do you have any suggestions regarding borrower requirements or Program enhancements that CBCMA should consider to reduce risks to the MMIF?
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