Federal Housing Administration
Risks to the Mutual Mortgage Insurance Fund and the Agency's Operations Gao ID: GAO-12-277T December 1, 2011The Federal Housing Administration (FHA) has helped millions purchase homes by insuring private lenders against losses from defaults on single-family mortgages. In recent years, FHA has experienced a dramatic increase in its market role due, in part, to the contraction of other mortgage market segments. The increased reliance on FHA mortgage insurance highlights the need for FHA to ensure that it has the proper controls in place to minimize financial risks while meeting the housing needs of borrowers. This statement discusses (1) changes in the financial condition of FHA's fund used to insure mortgages--the Mutual Mortgage Insurance Fund (Fund)--and the budgetary implications of these changes; (2) how FHA evaluates the financial condition of the Fund; and (3) steps FHA has taken to assess and manage risks. This statement is drawn from a recent report on FHA's oversight capacity (GAO-12-15) as well as a report issued in September 2010 on the financial condition of the Fund (GAO-10-827R). GAO also obtained updated information on the status of the Fund from the recently issued actuarial report on the Fund.
For the third consecutive year, FHA reported that the Fund's capital ratio (the ratio of economic value to insurance-in-force) has not met the 2 percent statutory minimum (see below). FHA cites declines in the Fund's economic value due to higher-than-expected defaults, claims, and losses. At the same time, the other component of the ratio, FHA's insurance-in-force, has grown rapidly. The Fund's condition also worsened from a budgetary perspective, with balances in the Fund's capital reserve account reaching new lows. If the account were depleted, FHA would require more funds to help cover costs on insurance issued to date. FHA enhanced methods for assessing the Fund's financial condition but has not yet addressed GAO's 2010 recommendation for improving the reliability of its estimates. It relies on a single economic forecast, which does not fully account for variability in future house prices and interest rates. An approach that would simulate hundreds of economic paths for house prices and interest rates would improve the reliability of its capital ratio estimates. FHA has taken or plans a number of steps to better assess and manage risk. It created a risk office in 2010 and hired a consultant to recommend best practices. FHA plans to charter committees to evaluate risks at enterprise-wide and programmatic levels. It began a quality control initiative in the Office of Single Family Housing, in which program and field offices assess and report on risks. FHA also enhanced lender and appraiser reviews. While FHA's consultant recommended integrating risk assessments, the quality control and risk office activities currently remain separate efforts. Also, the Office of Single Family Housing has not annually updated assessments since 2009 as required. Without integrated and updated risk assessments that identify emerging risks, FHA lacks assurance it has identified all its risks. GAO previously made recommendations on modeling the Fund's financial condition, risk assessments, and human capital. FHA agreed with these recommendations and told GAO they have efforts underway to implement them.
GAO-12-277T, Federal Housing Administration: Risks to the Mutual Mortgage Insurance Fund and the Agency's Operations
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United States Government Accountability Office:
GAO:
Testimony:
Before the Committee on Financial Services, House of Representatives:
For Release on Delivery:
Expected at 10:00 a.m. EST:
Thursday, December 1, 2011:
Federal Housing Administration:
Risks to the Mutual Mortgage Insurance Fund and the Agency's
Operations:
Statement of Mathew J. Scirè, Director:
Financial Markets and Community Investment:
GAO-12-277T:
GAO Highlights:
Highlights of GAO-12-277T, a testimony before the Committee on
Financial Services, House of Representatives.
Why GAO Did This Study:
The Federal Housing Administration (FHA) has helped millions purchase
homes by insuring private lenders against losses from defaults on
single-family mortgages. In recent years, FHA has experienced a
dramatic increase in its market role due, in part, to the contraction
of other mortgage market segments. The increased reliance on FHA
mortgage insurance highlights the need for FHA to ensure that it has
the proper controls in place to minimize financial risks while meeting
the housing needs of borrowers.
This statement discusses (1) changes in the financial condition of
FHA‘s fund used to insure mortgages-”the Mutual Mortgage Insurance
Fund (Fund)-”and the budgetary implications of these changes; (2) how
FHA evaluates the financial condition of the Fund; and (3) steps FHA
has taken to assess and manage risks.
This statement is drawn from a recent report on FHA‘s oversight
capacity (GAO-12-15) as well as a report issued in September 2010 on
the financial condition of the Fund (GAO-10-827R). GAO also obtained
updated information on the status of the Fund from the recently issued
actuarial report on the Fund.
What GAO Found:
For the third consecutive year, FHA reported that the Fund‘s capital
ratio (the ratio of economic value to insurance-in-force) has not met
the 2 percent statutory minimum (see below). FHA cites declines in the
Fund‘s economic value due to higher-than-expected defaults, claims,
and losses. At the same time, the other component of the ratio, FHA‘s
insurance-in-force, has grown rapidly. The Fund‘s condition also
worsened from a budgetary perspective, with balances in the Fund‘s
capital reserve account reaching new lows. If the account were
depleted, FHA would require more funds to help cover costs on
insurance issued to date.
FHA enhanced methods for assessing the Fund‘s financial condition but
has not yet addressed GAO‘s 2010 recommendation for improving the
reliability of its estimates. It relies on a single economic forecast,
which does not fully account for variability in future house prices
and interest rates. An approach that would simulate hundreds of
economic paths for house prices and interest rates would improve the
reliability of its capital ratio estimates.
FHA has taken or plans a number of steps to better assess and manage
risk. It created a risk office in 2010 and hired a consultant to
recommend best practices. FHA plans to charter committees to evaluate
risks at enterprise-wide and programmatic levels. It began a quality
control initiative in the Office of Single Family Housing, in which
program and field offices assess and report on risks. FHA also
enhanced lender and appraiser reviews. While FHA‘s consultant
recommended integrating risk assessments, the quality control and risk
office activities currently remain separate efforts. Also, the Office
of Single Family Housing has not annually updated assessments since
2009 as required. Without integrated and updated risk assessments that
identify emerging risks, FHA lacks assurance it has identified all its
risks. Further, human capital presents challenges. FHA has not created
a systematic workforce plan to identify critical skills and skill
gaps. Such a plan will be needed because high percentages of staff are
eligible to retire soon. Without a workforce planning process that
includes succession planning, FHA‘s ability to systematically identify
workforce needs is limited.
Figure: Estimate of the Fund‘s Capital Ratio, 2001-2011:
[Refer to PDF for image: vertical bar graph]
Minimum capital ratio: 2.0%.
Fiscal year: 2001;
Capital ratio: 4.0%.
Fiscal year: 2002;
Capital ratio: 4.9%.
Fiscal year: 2003;
Capital ratio: 5.6%.
Fiscal year: 2004;
Capital ratio: 5.9%.
Fiscal year: 2005;
Capital ratio: 6.5%.
Fiscal year: 2006;
Capital ratio: 7.4%.
Fiscal year: 2007;
Capital ratio: 7.0%.
Fiscal year: 2008;
Capital ratio: 3.2%.
Fiscal year: 2009;
Capital ratio: 0.5%.
Fiscal year: 2010;
Capital ratio: 0.5%.
Fiscal year: 2011;
Capital ratio: 0.2%.
Source: GAO analysis of FHA data.
[End of figure]
What GAO Recommends:
GAO previously made recommendations on modeling the Fund‘s financial
condition, risk assessments, and human capital. FHA agreed with these
recommendations and told GAO they have efforts underway to implement
them.
View [hyperlink, http://www.gao.gov/products/GAO-12-277T]. For more
information, contact Mathew J. Scirè at (202) 512-8678 or
sciremj@gao.gov.
[End of section]
Chairman Bachus, Ranking Member Frank, and Members of the Committee:
I am pleased to be here to participate in today's hearing on the
financial condition of the Federal Housing Administration's (FHA)
Mutual Mortgage Insurance Fund (Fund). As you know, FHA has helped
millions of families purchase homes through its single-family mortgage
insurance programs and insures almost all of its single-family
mortgages under the Fund.
FHA reported in November 2011 that for the third consecutive year, the
Fund was not meeting the statutory 2 percent capital reserve
requirement, as measured by the Fund's estimated capital ratio--that
is, the Fund's economic value divided by the insurance-in-force.
Although the Fund historically has produced budgetary receipts for the
federal government, a weakening in the performance of FHA-insured
loans has heightened the possibility that FHA could require additional
funds to help cover its costs on insurance issued to date. The
increased reliance on FHA mortgage insurance highlights the need for
FHA to ensure that it has the proper controls in place to minimize
financial risks while meeting the housing needs of borrowers.
My statement today is based on a September 2010 report about FHA's
financial condition and a report issued in November of this year about
the agency's risk assessment and human capital management.[Footnote 1]
Specifically, I will discuss (1) how estimates of the Fund's capital
ratio changed in recent years and the budgetary implications of
changes in the Fund's financial condition, (2) how FHA and its
actuarial review contractor evaluate the financial condition of the
Fund, and (3) steps FHA has taken to manage and assess risks. I also
will briefly discuss our report on the risks faced by the Government
National Mortgage Association (Ginnie Mae), which was released today.
[Footnote 2]
To do this work, we analyzed actuarial reviews of the Fund and federal
budget documents, and interviewed FHA officials, staff from FHA's
actuarial review contractor, and selected housing market researchers.
We also analyzed data on FHA's business volume, market share,
workload, and staff and contractor resources. We reviewed
documentation on the proposed structure and functions of FHA's Office
of Risk Management and Regulatory Affairs and the Office of Single
Family Housing's internal quality control initiative. Finally, we
reviewed changes to FHA guidance that address risks associated with
lenders and appraisers and documentation related to workforce and
succession planning. Our study of Ginnie Mae assessed operational
risks and financial exposure. We reported on Ginnie Mae volume and
market share, reviewed guidance and Ginnie Mae's credit subsidy
calculations and estimation model, and interviewed agency officials
and others. The reports include a detailed description of our scope
and methodology.
The work on which this statement was based was performed from
September 2009 to November 2011 in accordance with generally accepted
government auditing standards. Those standards require that we plan
and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on
our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit
objectives.
Background:
Under the Federal Credit Reform Act of 1990 (FCRA), FHA and other
federal agencies must estimate the net lifetime costs--known as credit
subsidy costs--of their loan insurance or guarantee programs and
include the costs to the government in their annual budgets. Credit
subsidy costs represent the net present value of expected lifetime
cash flows, excluding administrative costs.[Footnote 3] When estimated
cash inflows exceed expected cash outflows, a program is said to have
a negative credit subsidy rate and generates offsetting receipts that
reduce the federal budget deficit. When the opposite is true, the
program is said to have a positive credit subsidy rate--and therefore
requires appropriations. Generally, agencies must produce annual
updates of their subsidy estimates--reestimates--on the basis of
information about actual performance and estimated changes in future
loan performance. FCRA recognized the difficulty of making credit
subsidy estimates that mirrored actual loan performance and provides
permanent and indefinite budget authority for reestimates that reflect
increased program costs. Upward reestimates increase the federal
budget deficit unless accompanied by reductions in other government
spending or an increase in receipts.
The Omnibus Budget Reconciliation Act of 1990 required the Secretary
of the Department of Housing and Urban Development (HUD) to take steps
to ensure that the Fund attained a capital ratio of at least 2 percent
by November 2000 and maintained at least a 2 percent ratio at all
times thereafter.[Footnote 4] It also required an annual independent
actuarial review of the economic net worth and soundness of the Fund.
The annual actuarial review is now a requirement in the Housing and
Economic Recovery Act of 2008, which also requires that the Secretary
of HUD annually report to Congress on the results of the review.
Federal agencies face a number of risks. In the case of agencies with
loan guarantee or insurance programs, they can face credit risks that
include borrower default risk, which arises as borrowers become unable
to make payments on insured mortgages. Agencies with these programs
also face counterparty risk. That is, an agency may suffer losses due
to weaknesses or uncertainties in the work of its counterparties--in
this example, lenders and appraisers. And all agencies face
operational risks, the risk of loss resulting from inadequate or
failed internal processes or people (in terms of staff numbers,
training, and skills), or external events. For this statement, we
focus on operational risks related to FHA's staffing and contractor
capacity to process increasing workloads.
The Fund's Financial Condition Continues to Worsen, Increasing the
Possibility That FHA Will Require Additional Funds:
The Fund's capital ratio dropped sharply in 2008 and fell below the
statutory minimum in 2009, when economic and market developments
created conditions that simultaneously reduced the Fund's economic
value (the numerator of the ratio) and increased the insurance-in-
force (the denominator of the ratio).[Footnote 5] According to annual
actuarial reviews of the Fund, the capital ratio fell from about 7
percent in 2006 to 3 percent in 2008 and 0.5 percent in 2009 (see
figure 1). For 2010 and 2011, the ratios were 0.5 and 0.24 percent,
respectively.
Figure 1: Estimates of the Fund's Capital Ratio, 2001-2011:
[Refer to PDF for image: vertical bar graph]
Minimum capital ratio: 2.0%.
Fiscal year: 2001;
Capital ratio: 4.0%.
Fiscal year: 2002;
Capital ratio: 4.9%.
Fiscal year: 2003;
Capital ratio: 5.6%.
Fiscal year: 2004;
Capital ratio: 5.9%.
Fiscal year: 2005;
Capital ratio: 6.5%.
Fiscal year: 2006;
Capital ratio: 7.4%.
Fiscal year: 2007;
Capital ratio: 7.0%.
Fiscal year: 2008;
Capital ratio: 3.2%.
Fiscal year: 2009;
Capital ratio: 0.5%.
Fiscal year: 2010;
Capital ratio: 0.5%.
Fiscal year: 2011;
Capital ratio: 0.2%.
Source: GAO analysis of FHA data.
[End of figure]
In its recent report to Congress, HUD cited several reasons for the
declines from 2010 to 2011. These included:
* Continuing declines in home prices. Forecasts for the 2010 actuarial
study predicted house price declines of 2.8 percent before bottoming
in the middle of 2011. This year's forecasts--dated July 2011--
predicted negative growth of 5.6 percent for FHA's single-family
portfolio in 2011. Higher-than-expected declines in house values
contributed to both higher defaults and claims and higher loss-on-
claim than anticipated last year.
* More loans, particularly from the housing bubble years of 2006-2008
were in serious delinquency, and a significant percentage had been
there for more than one year. Claims become the most likely outcome
for extended delinquency loans, many of which are in foreclosure.
* For the first time, the actuarial calculations built in factors
recognizing the elevated re-default potential from the increased
number of active loans with a previous serious delinquency (3 months
or more).
* The independent actuaries also made a decision to treat foreclosure
actions likely affected by so called robosigning problems as expected
claims in 2012.[Footnote 6]
In reviewing the components of the capital ratio, the combination of a
relatively stable economic value (numerator of the ratio) and a
declining insurance-in-force (denominator) over much of the decade
increased the capital ratio. However, since 2008, the economic value
has fallen as the insurance-in-force has risen, dramatically lowering
the capital ratio (see figure 2).
Figure 2: Estimates of the Fund's Economic Value and Insurance-in-
force, 2001-2011:
[Refer to PDF for image: combined vertical bar and line graph]
Fiscal year: 2001;
Economic value: $18.5 billion;
Amortized insurance-in-force: $459 billion.
Fiscal year: 2002;
Economic value: $22.6 billion;
Amortized insurance-in-force: $467 billion.
Fiscal year: 2003;
Economic value: $22.7 billion;
Amortized insurance-in-force: $407 billion.
Fiscal year: 2004;
Economic value: $22.0 billion;
Amortized insurance-in-force: $373 billion.
Fiscal year: 2005;
Economic value: $21.6 billion;
Amortized insurance-in-force: $332 billion.
Fiscal year: 2006;
Economic value: $22.0 billion;
Amortized insurance-in-force: $299 billion.
Fiscal year: 2007;
Economic value: $21.3 billion;
Amortized insurance-in-force: $305 billion.
Fiscal year: 2008;
Economic value: $12.9 billion;
Amortized insurance-in-force: $401 billion.
Fiscal year: 2009;
Economic value: $3.6 billion;
Amortized insurance-in-force: $685 billion.
Fiscal year: 2010;
Economic value: $4.7 billion;
Amortized insurance-in-force: $931 billion.
Fiscal year: 2011;
Economic value: $2.6 billion;
Amortized insurance-in-force: $1.1 trillion.
Source: GAO analysis of FHA data.
[End of figure]
At the same time, the Fund's condition has worsened from a budgetary
perspective. Historically, FHA has estimated that its loan insurance
program was a negative subsidy program (that is, estimated cash
inflows exceeded expected cash outflows). On the basis of these
estimates, FHA accumulated substantial balances in a budgetary account
known as the capital reserve account, which holds reserves in excess
of those needed for estimated credit subsidy costs and helps cover
unanticipated increases in those costs such as higher-than-expected
claims. Reserves needed to cover estimated subsidy costs are held in
the Fund's financing account.[Footnote 7]
However, in recent years the capital reserve account has covered large
upward reestimates of FHA's credit subsidy costs through transfers to
the financing account. As a result, balances in the capital reserve
account fell dramatically--from $22 billion at the end of 2007 to $4.4
billion by the end of 2010 (see figure 3). If the reserve account were
to be depleted, FHA would need to draw on permanent and indefinite
budget authority to cover additional increases in estimated credit
subsidy costs. FHA's latest annual report to Congress raises the
possibility that if house prices decline in 2012, the expected future
losses on the current, outstanding portfolio could exceed current
capital resources. These would be offset by the expected net receipts
from the new 2012 cohort of loans. But, according to HUD, if house
prices were to decline in 2012 by an amount rivaling that of 2011,
these new loans would not be expected to generate sufficient net
receipts to offset any potential decline in value of the current
outstanding portfolio, which could necessitate assistance from the
Department of the Treasury (Treasury). Under one stress scenario in
which house prices decline by 13.7 percent in 2011, rather than the
5.6 percent assumed in the baseline scenario, and house prices decline
another 1.3 percent in 2012, HUD estimates that it may require $13
billion in assistance from Treasury to ensure the financing account
had sufficient loss reserves.
Figure 3: End-of-Year Balances in the Fund's Capital Reserve Account,
2002-2010:
[Refer to PDF for image: vertical bar graph]
Fiscal year: 2002;
End-of-year balance: $22.8 billion.
Fiscal year: 2003;
End-of-year balance: $26.2 billion.
Fiscal year: 2004;
End-of-year balance: $23.5 billion.
Fiscal year: 2005;
End-of-year balance: $23.3 billion.
Fiscal year: 2006;
End-of-year balance: $22 billion.
Fiscal year: 2007;
End-of-year balance: $22.4 billion.
Fiscal year: 2008;
End-of-year balance: $19.1 billion.
Fiscal year: 2009;
End-of-year balance: $10.6 billion.
Fiscal year: 2010;
End-of-year balance: $4.4 billion.
Source: GAO analysis of federal budget data.
[End of figure]
FHA's Current Methodology for Assessing the Fund's Condition Does Not
Fully Account for Future Economic Volatility:
As we reported in September 2010, FHA and its actuarial review
contractor enhanced their methods for assessing the Fund's financial
condition but still were addressing other methodological issues that
could affect the reliability of estimates of the capital ratio. Annual
actuarial reviews of the Fund use statistical models to estimate the
probability that loans will prepay or result in insurance claims on
the basis of certain loan and borrower characteristics (such as loan-
to-value ratios and borrower credit scores) and key economic variables
(such as house prices and interest rates).[Footnote 8] FHA and its
contractor have enhanced these models in recent years, by
incorporating additional variables related to loan performance and
developed an additional model to predict loss rates on insurance
claims. Also, consistent with recommendations we made in a prior
report, in 2003 the actuarial reviews began to analyze the impact of
more pessimistic economic scenarios--for example, nationwide declines
in home prices--than they did previously.[Footnote 9]
However, the current methodology is significantly limited by its
reliance on a single economic forecast to produce the estimate of the
capital ratio that is used to determine if the Fund is meeting the 2
percent capital reserve requirement. This approach does not fully
account for the variability in future house prices and interest rates
that the Fund may face. As a result, baseline estimates of the capital
ratio may tend to underestimate insurance claims and mortgage
prepayments and therefore may tend to overestimate the Fund's economic
value. In a November 2003 report, the Congressional Budget Office
concluded that FHA could project the Fund's cash flows more accurately
by using an approach (stochastic modeling) that involves running
simulations of hundreds of different economic paths to produce a
distribution of capital ratio estimates.[Footnote 10]
Given the uncertainty that always surrounds estimates of future
economic activity, the report we issued last year recommended that HUD
require the actuarial review contractor to use stochastic simulation
of future economic conditions, including house prices and interest
rates, to estimate the Fund's capital ratio and include the results of
this analysis in FHA's annual report to Congress on the financial
status of the Fund. However, the most recent annual report does not
include an estimate of the Fund's capital ratio using this technique.
In response to our 2010 report, FHA officials told us that they were
planning to require the actuarial review contractor to use a
stochastic simulation model for the 2011 actuarial review. But, these
officials said that the model would be used to examine the
implications of extreme economic scenarios on the Fund and decisions
about using the model to estimate the Fund's capital ratio had not
been made.
FHA Has Taken Steps to Address Risks, but Has Yet to Implement a
Comprehensive Risk-Assessment Strategy:
FHA faces risks resulting from its operations. FHA's loan volume grew
significantly from 2006 to 2010. In 2006, FHA insured almost half a
million loans, totaling $70 billion in mortgage insurance. By 2010, it
insured 1.7 million loans, or about $319 billion in mortgage
insurance. During the same time period, FHA's single-family staff
increased 8 percent, from 932 employees in 2006 to 1,011 employees in
2010, while increases in key workload areas often surpassed 100
percent:
* Staff in the homeownership centers‘ Processing and Underwriting
Division grew at a slower rate (22 percent) than key workload items,
particularly volume-driven loan reviews (which increased by more than
100 percent).
* Increases in contractor staff and workload related to management of
foreclosed or real estate-owned properties were substantial, but
noncontractor staff levels increased at more modest levels.
* Loss mitigation actions more than doubled from 2006 to 2010, while
loss mitigation staff levels remained relatively constant.[Footnote 11]
Although FHA Worked to Address Credit and Operational Risk, It Has Not
Yet Put a Comprehensive Strategy in Place:
Although FHA has taken steps to assess credit and operational risks
facing its single-family insurance programs, its current risk-
assessment strategy is not comprehensive because it is not integrated
across the agency and lacks annual assessments and mechanisms to
anticipate changing conditions. To address credit risk and help
improve the financial condition of the Fund (which is supported by
borrower premiums), FHA raised premiums and made or proposed policy or
underwriting changes. For example, in April 2011 FHA increased its
annual insurance premiums from 0.85 percent to 1.10 percent for
borrowers with 30-year loans with initial loan-to-value ratios of 95
percent or less and from 0.90 percent to 1.15 percent for borrowers
with 30-year loans with initial loan-to-value ratios greater than 95
percent. Additionally, FHA increased down-payment requirements for
borrowers with lower credit scores. FHA also has proposed reducing
allowable seller contributions at closing, thereby helping to ensure
that buyers put more of their own funds into the home purchase. In
addition, FHA is in the process of revising its mortgage scorecard
algorithm, to recognize the effect of various risk elements not
currently discerned by the scorecard and determine what cases warrant
manual underwriting.[Footnote 12] According to FHA, these revisions
are in the early stages, and no completion date has been set.
To address operational risks and improve its risk-assessment strategy,
in 2010 FHA received congressional approval to establish the Office of
Risk Management and Regulatory Affairs and create the position of
Deputy Assistant Secretary for Risk Management and Regulatory Affairs,
which reports directly to the Assistant Secretary for Housing-FHA
Commissioner. To provide assistance to the Office of Risk Management
(one of the offices within the Office of Risk Management and
Regulatory Affairs) in developing a risk-management strategy and
organizational structure and establishing risk-management policies and
processes, FHA hired a consultant to produce a comprehensive report
and recommend best practices for its operation.[Footnote 13] According
to FHA officials, FHA plans to adopt the consultant's recommendation
to establish an enterprise risk committee to address overall risk to
the organization and a second tier of committees to address program
and operational risks. In addition, in 2009 the Office of Single
Family Housing implemented an internal quality control initiative at
headquarters and the four homeownership centers. For the areas
identified as high-risk, headquarters and the homeownership center
divisions developed plans to document control objectives and
established a monitoring strategy in which each homeownership center
submits quarterly reports to headquarters on the effectiveness of the
controls, including the status of any mitigation efforts.
However, FHA's risk-assessment strategy raises several issues. First,
FHA's current risk-assessment strategy is not comprehensive because it
is not integrated throughout the organization. While the consultant
recommended that FHA integrate risk assessment and reporting
throughout the organization, currently Single Family Housing's quality
control activities and the Office of Risk Management's activities
remain separate efforts. FHA officials noted that until the Office of
Risk Management set up a governance process, the integration suggested
by the consultant would not be possible. In the meantime, they stated
that every effort was being made to help ensure that the Office of
Risk Management's activities complemented program office activities.
Second, contrary to HUD guidance, Single Family Housing has not
conducted an annual, systematic review of risks to its program and
administrative functions. According to an official in the Office of
Single Family Housing, although management intended to conduct an
annual assessment, the dates slipped because of changes in senior
leadership in Single Family Housing and few staff were available to
perform assessments (because of attrition and increased workload).
Finally, Single Family Housing's current risk-assessment efforts do
not include procedures for anticipating potential risks presented by
changing conditions. The consultant's report proposes a reporting
process and templates for identifying emerging risks and provides
specific examples. Office of Risk Management officials told us that
once they are operational the risk committees eventually would
determine the exact design and content of the reports and templates.
Moreover, implementation and integration of the new risk-assessment
strategy and planned tools has been slow because of delays in defining
the Office of Risk Management's authority, difficulty filling new
staff positions in the Office of Risk Management, and changes in FHA
leadership.
All these factors limit FHA's effectiveness in identifying, planning
for, and addressing risk. More specifically, without an integrated
risk-assessment strategy, certain risks may not be fully addressed at
the operational level in a way that minimizes risk to the insurance
programs; without annual reassessments of its risks, Single Family
Housing lacks assurance that its quality control efforts address all
its risks; and without ongoing mechanisms in place to anticipate and
address new or emerging risks, FHA lacks a systematic approach to help
the agency identify, analyze, and formulate timely plans to respond
most effectively to changed conditions and risks. Therefore, we
recommended that FHA (1) integrate the internal quality control
initiative of the Office of Single Family Housing into the operational
risk processes of the Office of Risk Management, (2) conduct an annual
risk assessment, and (3) establish ongoing mechanisms--such as use of
the report templates from the 2010 consultant's report--to anticipate
and address risks that might be caused by changing conditions. FHA
agreed with the recommendations and stated that it either was working
toward achieving the recommendations or had plans to do so in the very
near future. For example, FHA said it would leverage or integrate
existing risk management efforts as soon as the Office of Risk
Management's final governance structure and risk management strategies
were in place. The agency also stated that the Office of Risk
Management would conduct an annual risk assessment as a component of
its overall risk management strategy. It stressed that ongoing
mechanisms to anticipate and address risks related to changing
conditions would be part of the office's strategy.
FHA Has Taken Steps to Address Counterparty Risks, but Continues to
Face Human Capital Challenges:
With growth in loan volume, the number of lenders and appraisers (or
counterparties) participating in FHA's single-family programs also has
grown. The total number of FHA-approved lenders increased 24 percent,
from 10,370 in 2006 to 12,844 in 2010. The number of FHA-approved
appraisers increased approximately 67 percent from 33,553 in 2006 to
56,192 in 2010.
However, FHA has made recent changes to address risks posed by its
lenders and appraisers. For example, on May 20, 2010, FHA stopped
approving new loan correspondents.[Footnote 14] As of January 1, 2011,
existing loan correspondents could no longer participate in FHA
programs. Former loan correspondents now can participate only as third-
party originators through sponsorship by FHA-approved lenders. As a
result, as of September 2011, FHA had almost 3,700 approved lenders.
Furthermore, the agency has increased the net worth requirement for
approved lenders. On May 20, 2011, FHA increased the requirement for
existing lenders to $1 million, except for lenders classified as small
under the Small Business Administration's size standards (their
requirement increased to $500,000). As of May 20, 2013, FHA will
require a net worth of $1 million for all lenders, plus 1 percent of
the total loan volume in excess of $25 million, to a maximum required
net worth of $2.5 million.[Footnote 15] To help ensure that lenders
and appraisers follow its policies and procedures, FHA also has
enhanced the criteria used to select loans for technical reviews.
Specifically, since May 3, 2010, the agency has considered high-risk
loan or borrower characteristics, such as certain types of refinanced
loans and loans to borrowers with low credit scores. Additionally, FHA
increased the number of risk factors used to target lenders for
review. FHA also has revised its approach for overseeing appraisers.
FHA has addressed staffing and training needs and succession planning
to some extent, but it lacks plans that strategically address future
workforce needs, including replacing retiring staff. Although
workforce planning practices used by leading organizations include
defining critical skills and skill gaps, FHA's current approach does
not have mechanisms for doing so. FHA previously had a multiyear
workforce plan that identified the critical competencies; analyzed
skills and competencies, including gaps; and proposed comprehensive
strategies to address these gaps, but has not created another such
plan.[Footnote 16] Instead, FHA has relied on occasional Resource
Estimation and Allocation Process studies and annual managerial
assessments of staffing and training needs.[Footnote 17]
FHA also currently does not have a succession plan, although a HUD
plan for 2006-2009 identified mission-critical positions, analyzed
existing staff competencies, assessed the number of retirement-
eligible employees, and determined the probability of near-term
retirements.[Footnote 18] Succession planning is particularly
important because almost 50 percent of Single Family Housing
headquarters staff are eligible to retire in the next 3 years. The
percentage of staff eligible to retire at the homeownership centers is
even higher--63 percent.
While FHA has taken some steps to address succession planning, they
have been limited. FHA implemented two initiatives focused on
succession planning. The first, begun in 2010, was intended to help
ensure that, at any given time, at least two additional supervisors,
managers, or executives could perform the work of each supervisor,
manager, or executive. However, this does not apply to staff positions
beyond management. The second initiative also began in 2010. Its goal
is to train and develop staff. Neither initiative assesses the number
of retirement-eligible employees in critical positions as required by
HUD guidance. According to FHA officials, as resources have dwindled,
they have considered all their positions to be critical.
According to FHA officials, plans to update their workforce and
succession plans were suspended. In 2007-2009, FHA had a workforce
planning process designed to identify critical skill gaps and a
strategy for addressing these gaps. According to the officials, HUD
told FHA to stop this initiative in 2009 because HUD was going to
implement a workforce planning process for the entire department.
However, the effort never came to fruition because of funding
shortages. Without a more comprehensive workforce planning process
that includes succession planning, FHA's ability to systematically
identify the workforce needed for the future and plan for upcoming
retirements is limited. Therefore, we recommended that FHA develop
workforce and succession plans for the Office of Single Family
Housing. FHA agreed, stating that it would develop a formal workforce
plan and had efforts underway to develop a succession plan.
Ginnie Mae's Risk Management and Cost Modeling Require Continuing
Attention:
We released a report today about Ginnie Mae, which has experienced a
substantial increase in the volume of its business since 2007 as the
volume of federally insured or guaranteed mortgages increased. Ginnie
Mae is a wholly owned government corporation in HUD, which guarantees
the timely payment of principal and interest on mortgage-backed
securities (MBS) backed by pools of federally insured or guaranteed
mortgage loans, such as FHA loans. As of 2010, Ginnie Mae guaranteed
more than $1 trillion in outstanding MBS composed primarily of FHA-
insured mortgages. The growth in outstanding Ginnie Mae-guaranteed MBS
resulted in an increased financial exposure for the federal
government. Nonetheless, Ginnie Mae's revenues exceeded its costs, and
it has accumulated a capital reserve of about $14.6 billion.
Ginnie Mae has taken steps to better manage operational and
counterparty risks and has several initiatives planned or underway.
The operational risks the agency may face include limited staff,
substantial reliance on contractors, and the need for modernized
information systems. Ginnie Mae plans to increase its staff levels,
complete a reorganization, and implement recommendations related to
contracting. For Ginnie Mae, counterparty risk is the risk that
issuers of Ginnie Mae MBS fail to provide investors with monthly
principal and interest payments. To manage its counterparty risk,
Ginnie Mae has processes in place to oversee MBS issuers that include
approval, monitoring, and enforcement and has revised its approval and
monitoring procedures. For example, in 2010 Ginnie Mae increased the
minimum net worth requirement for issuers of Ginnie Mae-guaranteed MBS
to $2.5 million. But, planned initiatives to enhance its risk-
management processes for issuers, including its tracking and reporting
systems, have not been fully implemented. It will be important for
Ginnie Mae to complete its initiatives related to operational and
counterparty risk as soon as practicable.
In developing inputs and procedures for the model used to forecast
costs and revenues, Ginnie Mae did not consider certain practices
identified in Federal Accounting Standards Advisory Board (FASAB)
guidance for preparing cost estimates of federal credit programs.
Ginnie Mae has not developed estimates based on the best available
data, performed sensitivity analyses to determine which assumptions
have the greatest impact on the model, or documented why it used
management assumptions rather than available data. By not fully
implementing practices in FASAB guidance that GAO believes represent
sound internal controls for models, Ginnie Mae's model may not use
critical data that could affect the agency's ability to provide well-
informed budgetary cost estimates and financial statements. This may
limit Ginnie Mae's ability to accurately report to Congress the extent
to which its programs represent a financial exposure to the government.
We recommended that the Secretary of Housing and Urban Development
direct Ginnie Mae to take steps to ensure its model more closely
follows certain practices identified in Federal Accounting Standards
Advisory Board guidance for estimating subsidy costs of credit
programs. More specifically, Ginnie Mae should (1) assess and document
that it is using the best available data in its model and most
appropriate modeling approach, (2) conduct and document sensitivity
analyses to determine which cash flow assumptions have the greatest
impact on the model, (3) document how management assumptions are
determined, such as those for issuer defaults and mortgage buyout
rates, and (4) assess the extent to which management assumptions, such
as those for issuer defaults and mortgage buyout rates, can be
replaced with quantitative estimates. The President of Ginnie Mae
wrote that Ginnie Mae is working towards implementing our
recommendation for conducting sensitivity analyses relating to issuer
risk and behavior, but neither agreed nor disagreed with our other
specific recommendations. In addition, Ginnie Mae agreed with our
observation about the importance of completing ongoing and planned
initiatives for enhancing its risk-management processes, as soon as
practicable, to improve operations.
Mr. Chairman, Ranking Member Frank, and Members of the Committee, this
concludes my prepared statement. I would be happy to respond to any
questions that you may have at this time.
GAO Contact and Staff Acknowledgments:
For further information about this testimony, please contact Mathew J.
Scirè, Director, at 202-512-8678 or sciremj@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this statement. Individuals making key
contributions to this testimony include Paige Smith (Assistant
Director), Andy Pauline (Assistant Director), Steve Westley (Assistant
Director), Dan Alspaugh, Nadine Garrick Raidbard, John McGrail, Marc
Molino, José R. Peña, Beth Reed Fritts, Paul G. Revesz, and Barbara
Roesmann.
[End of section]
Footnotes:
[1] See GAO, Mortgage Financing: Opportunities to Enhance Management
and Oversight of FHA's Financial Condition, [hyperlink,
http://www.gao.gov/products/GAO-10-827R] (Washington, D.C.: Sept. 14,
2010) and GAO, Federal Housing Administration: Improvements Needed in
Risk Assessment and Human Capital Management, [hyperlink,
http://www.gao.gov/products/GAO-12-15] (Washington, D.C.: Nov. 7,
2011).
[2] GAO, Ginnie Mae: Risk Management and Cost Modeling Require
Continuing Attention, [hyperlink,
http://www.gao.gov/products/GAO-12-49] (Washington, D.C.: Nov. 14,
2011).
[3] For a mortgage insurance program, cash inflows consist primarily
of fees and premiums charged to insured borrowers and proceeds from
sales of foreclosed properties, and cash outflows consist mostly of
payments to lenders to cover the cost of claims.
[4] Pub. L. No. 101-508.
[5] Unless otherwise stated, the years shown in this testimony are
fiscal years.
[6] Robosigning refers to mortgage servicers' practice of having a
small number of employees sign a large number of affidavits and other
legal documents that mortgage companies subsequently submitted to
courts and other public authorities to execute foreclosures. For more
information, see GAO, Mortgage Foreclosures: Documentation Problems
Reveal Need for Ongoing Regulatory Oversight, [hyperlink,
http://www.gao.gov/products/GAO-11-433] (Washington, D.C.: May 2,
2011).
[7] The financing account records lifetime cash flows for loans
insured in 1992 and thereafter. It appears in the budget for
informational and analytical purposes but is not included in the
budget totals or budget authority or outlays.
[8] The loan-to-value ratio is the ratio of the amount of the mortgage
loan to the value of the home.
[9] GAO, Mortgage Financing: FHA's Fund Has Grown, but Options for
Drawing on the Fund Have Uncertain Outcomes, [hyperlink,
http://www.gao.gov/products/GAO-01-460] (Washington, D.C.: Feb. 28,
2001).
[10] Congressional Budget Office, Subsidy Estimates for FHA Mortgage
Guarantees, a CBO paper (Washington, D.C.: November 2003).
[11] Loss mitigation actions seek to minimize losses from potential
foreclosures by finding alternatives to foreclosure and helping
homeowners retain their homes, if possible.
[12] The purpose of the algorithm is to objectively measure the
borrower's risk of default quickly and efficiently by examining the
data the borrower provides on the loan application and the borrower's
credit score.
[13] McKinsey & Company, Building the ORM Organization, Close-out
Materials, a report prepared at the request of the Department of
Housing and Urban Development, December 2010.
[14] Loan correspondents were lenders that originated FHA-insured
loans--meaning that they could accept mortgage applications, obtain
employment verifications and credit histories on applicants, order
appraisals, and perform other tasks that precede the loan underwriting
process--but did not have direct endorsement authority. Direct
endorsement authority is the authority to underwrite loans and
determine their eligibility for FHA mortgage insurance without HUD's
prior review.
[15] Loan volume is defined as FHA single-family insured mortgages
originated, underwritten, purchased, or serviced during the prior
fiscal year.
[16] Department of Housing and Urban Development, Strategic Workforce
Plan, FY04 to FY08, Office of Housing, (Washington, D.C.: July 2004).
[17] Resource Estimation and Allocation Process studies establish a
staffing baseline for budget formulation and execution, strategic
planning, organizational and management analyses, and ongoing
management of staff resources.
[18] Department of Housing and Urban Development, Succession
Management Plan, Fiscal Year 2006-2009, (Washington, D.C.: September
2006).
[End of section]
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