Fed Program Fuels Mortgage Risk:

The federal government backs a program creating moral hazards and encouraging risky home loans. Why am I not suprprised? The WSJ reports:

Mortgages that allow consumers to put little if any money down when buying a home have largely disappeared as a financing option available from private lenders. But they are still available -- and growing more popular -- through a government-backed program.

That's raising concerns among critics who blame no-money-down mortgages for many of today's housing market woes. And while federal housing officials are moving to end the practice, for now home builders are promoting the programs to move unsold inventory. . . .

The offers -- including "100% financing" -- are made possible due to down-payment assistance programs run by nonprofit organizations. These programs are funded largely by home builders and also by private homeowners desperate to sell. The seller-funded groups provide enough down-payment money to buyers that they can qualify for a mortgage backed by the Federal Housing Administration, which requires at least a 3% down payment.

Supporters of the down-payment programs say they help the FHA fulfill its goal of assisting first-time home buyers. But critics say the programs will burden the government agency, and taxpayers, with bad loans. The FHA, which essentially is filling the void left by the collapse of the subprime market, renewed a push to eliminate the programs this month, after warning that above-average default rates for seller-assisted down-payment programs will force the agency to request a government subsidy for the first time in its 74-year history. The agency says it will need $1.4 billion next year.

spot:
I just got one of these loans and I was pretty shocked they were still available. For me it allowed me to get a home off of foreclosure and put the 15k or so that would have been a downpayment directly towards repairs. But yeah- after the deal I got a lot of my friends are trying to jump in because it does seem like a pretty big loophole.
6.24.2008 11:26am
Rhode Island Lawyer:
The WSJ totally overstates the risk from this program. The mortgage meltdown was caused by borrowers' inability to afford adjustable rate loans that reset after an initial teaser rate, not by the 100% financing aspect of the financing package. Take a look at the default rate for first time homebuyers who bought homes with financing from responsible lenders, such as state housing finance agencies. Those defalut rates are well below the national average, even where the homebuyer received 100% financing with second mortgages provided by nonprofits or government agencies. Why? Because their first mortgage was properly underwritten and did not have drastic rate resets built in. Standard and Poors said it best: "Housing Finance Agencies Are Mostly Immune From Subprime Lending Risks"
6.24.2008 11:42am
TLV (mail):
Professor Adler,

Did you even read the article? The federal government opposes the programs. In fact, the FHA is trying to eliminate them:
The FHA, which essentially is filling the void left by the collapse of the subprime market, renewed a push to eliminate the programs this month, after warning that above-average default rates for seller-assisted down-payment programs will force the agency to request a government subsidy for the first time in its 74-year history.
The FHA prohibits sellers from providing down payment assistance to buyers directly, but home builders are using a loophole that allows third-party nonprofits to provide down payment assistance. The FHA is trying to close that loophole. So the federal government is actually trying to eliminate the moral hazard and discourage risky home loans.

Before smugly condemning the federal government for not being as smart as you, you should make sure you're not saying something incredibly stupid.
6.24.2008 12:06pm
David M. Nieporent (www):
TLV, you do understand the difference between the FHA and "the government," right?
6.24.2008 12:21pm
Some Dude (mail):
FHA is opposing the bills. Senator Dodd et al. are trying to look like they are "doing something."

Oddly enough, the guy who proposed the bailout through the FHA, Senator Dodd, took $780,000 in loans from Countrywide Mortgage under the "Friends of Angelo" program. He denies any improper benefit, but the deal he got was worth $75,000 in savings over the course of his loans. Coincidentally, Countrywide (BofA) has the largest exposure to these exotic loans, and stand to gain Billions from Dodd's bailout bill.

I'm sure there's nothing to it, though. Probably just me being paranoid.
6.24.2008 1:11pm
D Palmer (mail):
When you have a loan over 90% you are not an owner, you are a renter. Worse than that, if you need to sell and move you can't, because at 93%+ of purchase price, if you sell for the same price as you paid to buy, transaction costs will probably be more than the equity in the property.

The idea that everybody should own a home is foolish and dangerous and the billions of dollars that banks and mortgage lenders have lost to-date and the substantial incremental increase in foreclosures in the past 12 months compared to the previous 8-10 years prove that.
6.24.2008 2:14pm
D Palmer (mail):
When you have a loan over 90% you are not an owner, you are a renter. Worse than that, if you need to sell and move you can't, because at 93%+ of purchase price, if you sell for the same price as you paid to buy, transaction costs will probably be more than the equity in the property.

The idea that everybody should own a home is foolish and dangerous and the billions of dollars that banks and mortgage lenders have lost to-date and the substantial incremental increase in foreclosures in the past 12 months compared to the previous 8-10 years prove that.
6.24.2008 2:14pm
Stormy Dragon (mail) (www):
Mortgages that allow consumers to put little if any money down when buying a home have largely disappeared as a financing option available from private lenders.


I'm settling on a 3% down private mortgage next week, so there are still private lenders out there offering low money down financing.
6.24.2008 2:24pm
autolykos:
I'm not going to call these downpayment assistance programs fraud, but they're dancing dangerously close to the line. Talk about exalting form over substance.
6.24.2008 4:01pm
Oren:
Stormy -- of course in a free market someone would give you such a loan if they are being compensated for risk.

autolykos, so long as the borrower doesn't misrepresent the source of the down payment, how is it fraud? Of course, if they represent the down-payment as their own money, that is genuine fraud.

I'm not sure to which of those two scenarios you are referring.
6.24.2008 4:16pm
Suzy (mail):
Is there any evidence that buyers who qualify in the normal way for an FHA loan by putting 3% down are a much greater default risk?

Because it sounds like what's happening is that buyers who normally could not qualify in this way are being allowed to qualify when desperate sellers put that money up just so that they can unload a property, without concern for whether the FHA turns to the taxpayers to foot the bill when buyers default.

That's no reason to condemn the practice of allowing low down payments, in general. The problem is sellers trying to foist their problems in the current market onto the FHA and, by extension, the taxpayer.
6.24.2008 4:22pm
autolykos:

autolykos, so long as the borrower doesn't misrepresent the source of the down payment, how is it fraud? Of course, if they represent the down-payment as their own money, that is genuine fraud.


Fraud includes both misstatements and omissions that are required to make statements made not misleading.

Here's how the scam works. FHA requires all homeowners to have at least 3% skin in the game so that they have an interest in keeping their house. Assume seller and buyer agree to a transaction involving a house worth $100,000, but buyer doesn't have the 3% needed to put down. Buyer (or more likely the broker) brings in a third party to front the 3%. Buyer and seller agree to knock the price of the house up to a little over $103,000 (to cover the 3% + the commission for the third party). The third party makes the 3% payment at closing and is immediately repaid the same payment plus their commission. Seller doesn't care because they still netted $100,000 (+ whatever the commission was). Buyer's happy because they got the house they wanted with FHA financing with no money down. The third party's happy because they got their commission. The only party that isn't happy is FHA, because the 3% downpayment requirement they instituted to encourage buyers to do the right thing was just obviated by a transaction without any economic rationale.

Now if the 3% requirement isn't necessary, it isn't necessary and should be eliminated. But if FHA is going to have a 3% downpayment requirement, it should be an actual requirement and people shouldn't be getting around it by engaging in sham transactions.
6.24.2008 4:47pm
Stormy Dragon (mail) (www):
Stormy -- of course in a free market someone would give you such a loan if they are being compensated for risk.
I realize that I was just refuting the overbroad claim that this practice is almost completely disappearing in the private market. It's only disappearing for the riskiest segment of the market.
6.24.2008 4:51pm
autolykos:
Suzy - It's not a seller problem, it's a buyer problem. The sellers aren't the ones who have to make the decision to continue making payments in the future. They're helping the buyers set into a situation that's involves moral hazard, but that's it. From the article:


The FHA estimates that down payments provided by nonprofit groups account for 34% of all 200,000 loans backed by the FHA so far this year, up from 18% in all of 2003 and less than 2% in 2000. And the agency says that borrowers are two to three times as likely to default on their payments when they receive a down payment from a nonprofit.


I assume the FHA has some way of tracking/estimating this and that they're not just pulling numbers out of thin air.
6.24.2008 4:54pm
spot:
Stormy- 3% down mortgages aren't that rare. I was able to use this program to put almost nothing down. I was able to borrow that 3% down payment from a third party. I just don't think that the bank would have approved me doing it if it weren't for the FHA backing the loan.
6.24.2008 5:08pm
TGGP (mail) (www):
Steve Sailer has an article on it at Taki's.
6.24.2008 5:12pm
Crackmonkeyjr (www):
As somewhat discussed above, loans with no down payment don't lead to foreclosures. The fact that you have paid a certain percentage of the amount of the mortgage has pretty much no effect on whether you can afford to make the monthly payments.

At most, you ability to pay the down payment is a flag as to whether you can afford to make the monthly payment as someone who has $10k in the bank is likely in a better financial situation than someone without such savings. That being said, you can measure risk in ways other than looking at whether a person can pay a lump sum upfront and this flag is not even all that reliable (would you rather lend money to someone working at McDonalds who just inherited $10k from a dead uncle or someone who has just graduated law school and is buying a house to provide a residence while he is making $150k per year at a job at a white shoe law firm that he just got?)

Not only that, but not having someone pay a down payment can actually help prevent foreclosure, as you will be leaving the person with more savings to cover a situation where they do run into financial trouble.

The only real drawback that I can see is in a situation such as California where all mortgages are non-recourse. A substantial down payment does a good job of getting the person invested in the house. If you go out and buy a $500,000 house with no down payment, and next year the housing market drops, leaving you with a $500k mortgage on a $200k house, you have a strong incentive to just walk away if the mortgage is non-recourse. If you paid a $50k down payment on the same house, your incentive to just walk away (and lose your down payment) decreases. This only really becomes a problem in very special circumstances though.
6.24.2008 6:02pm
Toby:
Autolykos correctly caught the first stage of fraud,but missed the second.

The Loan Originator will presumeable sell the secuitized loans as loans that complied with FHA standards, and therfore presumably have somewhat smaller risk than a no-skin-in-the-game loan. The originator, then, is preparing to commit further fraud on the purchaser of that package of loans....
6.24.2008 6:14pm
Oren:
Now if the 3% requirement isn't necessary, it isn't necessary and should be eliminated. But if FHA is going to have a 3% downpayment requirement, it should be an actual requirement and people shouldn't be getting around it by engaging in sham transactions.
Yes, that is indeed fraud. I would imagine it's fairly simple to write a clause into a mortgage contract:

"The down payment I placed is my/our money (in case of joint mortgages or whatnot) and was not provided by any third party"
6.24.2008 6:51pm
Suzy (mail):
I still don't see why this is exclusively or even mostly a buyer problem. Anyone who takes on debt is risking "moral hazard", at that rate. What's unusual about this case is that a person who otherwise wouldn't be able to obtain that loan, due to being a poorer credit risk, is being helped to get one. The people who truly make this possible are those who front the necessary cash, which means that they know going into the deal that the buyer is a poor risk. The seller and in most cases the loan originator (as Toby points out) don't care because they won't suffer any penalty, and just want to make a commission or unload a property that they'd have difficulty selling in this market. At least the buyer goes into the deal not expecting or wanting to lose the house; the same can't be said for the seller who puts up money to such a buyer. Meanwhile, the FHA and taxpayers are left holding the bag.
6.24.2008 7:51pm
Perseus (mail):
The only real drawback that I can see is in a situation such as California where all mortgages are non-recourse.

Seeing as how the California real estate market is so large and one of the major (now deflating) bubble markets fueled by this sort of exotic financing, the moral hazard becomes nontrivial.
6.24.2008 8:16pm
autolykos:

I still don't see why this is exclusively or even mostly a buyer problem. Anyone who takes on debt is risking "moral hazard", at that rate. What's unusual about this case is that a person who otherwise wouldn't be able to obtain that loan, due to being a poorer credit risk, is being helped to get one. The people who truly make this possible are those who front the necessary cash, which means that they know going into the deal that the buyer is a poor risk. The seller and in most cases the loan originator (as Toby points out) don't care because they won't suffer any penalty, and just want to make a commission or unload a property that they'd have difficulty selling in this market. At least the buyer goes into the deal not expecting or wanting to lose the house; the same can't be said for the seller who puts up money to such a buyer. Meanwhile, the FHA and taxpayers are left holding the bag.


If you're reading my posts to suggest that the sellers and loan originators are somehow free from fault, then you're misreading them. Frankly, the question of who is more culpable is irrelevant. The FHA needs to close this loophole and the people in government who are working to keep them open (such as the congressional black caucus) need to stop it.
6.24.2008 8:47pm
Aleks:
FHA mortgage standards are still very strict and should weed out the sorts of credit risks that fueled the recent bubble and its spectacular demise. The FHA requires ful diocmuyentation of income and assets-- no "liar loans". It makes sure that loan-to-value ratios make sense, that appraisals are honest, and that the borrower can indeed afford the loan given his income and other debt. Yes, this loophole needs to be looked at very critically, but I donlt think the FHA is going to find a ton of bad loans on its hands becaise of it as long as it keeps its other safeguards in place.
6.24.2008 9:36pm
TLV (mail):
David M. Nieporent,

Yes, I understand the difference between the FHA and "the government." Do you? The FHA isn't a GSE, you know.

Down-payment assistance programs are run by private nonprofit organizations, not the government. They were created specifically for the purpose of circumventing FHA regulations prohibiting sellers from providing down-payment assistance to buyers directly. That doesn't make them "government-backed." Calling them "government-backed program[s]" is like calling mortgage servicers government agencies.

Professor Adler goes even further, calling it a "fed program," which clearly shows that he has no idea what he's talking about.
6.24.2008 11:10pm
justacommenter (mail):
Couple of points here:

1) The federal government didn't create the mortage crisis we are in now ... greedy investors did by trying to charge people 9-20% for a home loan. That's the sort of greed that nobody can afford. So, naturally, people defaulted on such loans.

2) Even that didn't cause the crisis. The crisis was caused by an inability of the market to price the equities backing these loans. This, in turn, was caused by the fact that legally, the people who own these equties don't even really own the loans backing them. To put it another way, they can't prove in a court of law that they own them. That's what makes them worthless.

The government could do a LOT that it isn't doing to help homeowners, but the Democrats on the Senate Banking Committee are too busy stuffing their pockets with thinly-veiled bribes from Mozillo and Co and Citibank. And they're just the tip of the corruption iceberg. Actual real bribes are occurring that you haven't read about.

The government could insure deeds, for example, and end the monopoly pricing on virtually worthless title insurance that every purchaser must pay THOUSANDS OF DOLLARS for. Every. Single. Home. Loan. Why is this insurance required? Because the government keeps crappy records.

Will the government do this? Why no, they won't. And why not? Well, have any of you intrepid reporters asked who's getting money from the title insurers?
6.24.2008 11:11pm
cj (mail):
"Aleks": I can only assume you are somehow vested in defending the FHA. Per your comment:

"It [the FHA] makes sure that loan-to-value ratios make sense, that appraisals are honest, and that the borrower can indeed afford the loan given his income and other debt."

As an FHA borrower, I can assure you that *none of the above* was a factor in my home loan. None. I sincerely doubt I was the only borrower in FHA history to experience this. Your emperor has no clothes.
6.24.2008 11:55pm
JB:
Stormy -- of course in a free market someone would give you such a loan if they are being compensated for risk.

And in a free market with perfect information, that would work. The crisis happened because the loans were made in a mostly free market with very imperfect information. When the information was revealed to be pretty much totally incorrect, it became clear that nobody was being compensated for risk and the whole thing collapsed.

____

The home ownership debacle seems to me to be an instance of the fallacy of composition: For an individual person, it's better to own a home than to rent (except in the presence of a housing bubble). But for all of society, it is not better for everyone to be a homeowner.
6.25.2008 3:23am
JohnMc (mail) (www):
I am against the bail out in part for the moral hazards aspects. But I find it interesting that those that would say it is a bad idea due to moral hazard for housing, will then blissfully wave a hand and say it is quite proper to do so to bail out Bear Stearns and others in the financial community. The cover of course is -- " we must save the system..."

I would suggest that if the Bear Stearns of the world knew that failure meant exactly that there might have been some self constraint to not be so willy nilly with investments.
6.25.2008 10:06am
D Palmer (mail):
Justacommenter,

you said:
1) The federal government didn't create the mortage crisis we are in now ... greedy investors did by trying to charge people 9-20% for a home loan. That's the sort of greed that nobody can afford. So, naturally, people defaulted on such loans. If you couldn't afford the payment, don't take the loan. Much of the issue over high rates is low intro rate adjustables re-pricing to market and homeowners unable to refi because they don't have the equity. People took these loans to buy homes they could not otherwise afford, or to pull out equity to pay off credit cards or just spend. That makes the buyer the greedy one, not the lender. If you don't plan for the possibility that you might have to pay the higher rate then you are foolish and must pay the price.

2) Even that didn't cause the crisis. The crisis was caused by an inability of the market to price the equities backing these loans. This, in turn, was caused by the fact that legally, the people who own these equties don't even really own the loans backing them. To put it another way, they can't prove in a court of law that they own them. That's what makes them worthless. I'm not sure what you're saying here. The securitized pools are groups of mortgages secured by residential real estate. The pools are subdivided into 'tranches' based on risk levels. Lower tranches pay better rates to offset higher risks. If there is a default the higher tranches get paid off first. The problem with mortgage backed securities is that they were rated and priced as if the underlying mortages were as safe as US Treasuries. However, due to the substantial deterioration in underwriting standards, the explosion of gimmick loans such as 'no doc', the use of adjustable rate loans, and finally the unsustainable run up in real estate prices defaults have soared, the the value of the mortgages in the pool and the real estate that ultimately secures them have declined. The increase in risk has destroyed demand for these products leaving banks sitting on mortgages that they never intended to hold and would probably not have made if they didn't think that they would be able to offload the risk to the securitized markets.
6.25.2008 1:50pm