News Filter: Press Releases & Statements

Letter: Comments on CFPB’s Advance Notice of Proposed Rulemaking on the Qualified Mortgage Definition

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WASHINGTON — Lindsey Johnson, President of U.S. Mortgage Insurers (USMI), today released the following statement on the organization’s comment letter submitted in response to the Consumer Financial Protection Bureau’s (“the Bureau”) Advance Notice of Proposed Rulemaking on the “Qualified Mortgage (QM) Definition under the Truth in Lending Act (Regulation Z).”

“As takers of first-loss mortgage credit risk with more than six decades of expertise and experience underwriting and actively managing that risk, USMI members understand the need to balance prudent underwriting with a clear and transparent standard that maintains access to affordable and sustainable mortgage finance credit for home-ready borrowers. The upcoming expiration of the temporary QM category, often referred to as the “GSE Patch,” provides an important opportunity for the Bureau to assess what has developed within the marketplace since the enactment of the QM Rule. Notably, mortgage lending has been done with far greater diligence by market participants to ensure consumers have a reasonable ability-to-repay (ATR) and has resulted in a much stronger housing finance system. Further, the GSE Patch has played a critical role in maintaining credit availability. In our comments to the Bureau, we offer specific recommendations for replacing the current GSE Patch to establish a single transparent and consistent QM definition in a way to balance access to mortgage finance credit and proper underwriting guardrails to ensure consumers’ ATR. USMI’s recommendations include:

  • Maintaining the ATR and product restrictions as part of any updates to the QM definition to ensure discipline in the lending community and to protect consumers;
  • Retaining specific underwriting guardrails such as the current debt-to-income (DTI) component of the QM definition, but modifying the specific threshold to better serve consumers; and
  • Developing a single set of transparent compensating factors for loans with DTIs above 45 and up to 50 percent for defining QM across all markets, similar to how the GSEs, FHA, and VA use compensating factors in their respective markets today.

“Retaining specific thresholds in measuring a consumer’s income, assets, and financial obligations better serves consumers and ensures that the statutory and regulatory intent of measuring a consumer’s ATR is met. Further, adjusting the current DTI limit from 43% to 45% for all loans, and up to 50% for loans with accompanying compensating factors creates a more transparent and level playing field that provides greater certainty for borrowers and lenders and reduces the impact of the expiration of the GSE Patch. USMI believes that the development of a single transparent industry standard will facilitate greater consistency across all lending channels and ensure there is not market arbitrage to achieve QM status.

“USMI applauds the Bureau for undertaking the necessary process for updating this critical rule that is aimed at enhancing lending standards and consumer protection. We look forward to working with the Bureau as it seeks to implement any changes to this important rule.”

Following the release of the Bureau’s ANPR in July, USMI published a blog with observations and recommendations for replacing the GSE Patch.

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

 

Letter: Major Housing Industry Trades and Homeownership Advocates on Tax Treatment of MI Premiums

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USMI joined a coalition of housing finance organizations including the Mortgage Bankers Association, National Association of Home Builders, National Association of REALTORS®, and National Housing Conference, in sending a letter to U.S. House of Representatives Committee on Ways and Means Chairman Richard Neil. The undersigned organizations urged the committee to modify current law to make the mortgage insurance premium tax deduction permanent and to eliminate its income phaseout. As a diverse coalition of stakeholders in the housing finance system, they affirmed that the current AGI phaseout represents a burdensome eligibility criterion for American families to claim the mortgage insurance deduction and that millions more homeowners would benefit from a permanent extension that eliminates the AGI phaseout. Click here to read the letter.

Statement: Nomination of Julia Gordon to Serve as FHA Commissioner

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WASHINGTON — Lindsey Johnson, President of U.S. Mortgage Insurers (USMI), issued the following statement on the White House’s nomination of Julia Gordon to serve as Assistant Secretary for Housing, Federal Housing Commissioner, Department of Housing and Urban Development (HUD):

“USMI applauds the nomination of Julia Gordon to serve as Federal Housing Commissioner to lead the Federal Housing Administration (FHA). Gordon has broad experience in the housing finance system, specializing in supporting affordable homeownership and consumer protection policies for underserved markets. Her previous work, including nearly six years leading the National Community Stabilization trust (NCST), public service as manager of the single-family policy team at the Federal Housing Finance Agency (FHFA), and four years as senior policy counsel at the Center for Responsible Lending (CRL), will allow her to efficiently address the important issues facing the housing industry. We look forward to working closely with Gordon in seeking to promote a complementary, collaborative, and consistent housing finance system that enables sustainable homeownership for American families while also protecting taxpayers.”

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

Press Release: National Survey Confirms Low Housing Supply and Lack of Affordable Housing Among Biggest Homebuying Challenges for Minorities and Americans Overall

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2021 National Homeownership Market Survey Also Finds Most Americans Don’t Understand Availability of Low Down Payment Mortgage Options

WASHINGTON — U.S. Mortgage Insurers (USMI) today released its 2021 National Homeownership Market Survey that finds nearly 7 in 10 (69 percent) ranked lack of affordable housing and nearly 6 in 10 (57 percent) ranked low housing supply among the biggest homebuying challenges in the United States. The survey also revealed that many people continue to not understand the down payment requirements to purchase a home. Housing insecurity (66 percent) was also among the top concerns from respondents. Socioeconomic disparities – such as lower income, lack of intergenerational wealth, limited savings, and the percentage of monthly income dedicated to housing costs – were reported to make these challenges more acute. The survey also specifically looked at these responses by race to better understand minorities’ perceptions and challenges to homeownership.

“This survey underscores the need to address the nation’s undersupply of housing, and specifically affordable housing, because too many people are being left out of the market or face significant barriers to get into the housing market,” said Lindsey Johnson, President of USMI. “Our survey shows that low- to moderate-income households and underserved communities struggle to become homeowners due to several major factors including low housing supply, lack of affordable housing, and personal economic factors such as imperfect credit score or the inability to afford a 20 percent down payment.”

USMI’s survey found that when broken down by race these economic factors are even more pronounced. Seventy-four percent of African American and 65 percent of Hispanic respondents reported that in addition to the lack of affordable homes or low supply, the inability to save for a down payment (39 percent of all minorities) and imperfect credit history (37 percent of all minorities) are the biggest challenges they face when it comes to buying a home.

Housing insecurity during the pandemic was also a significant concern among survey respondents, particularly for minorities. The number one concern among African American and Hispanic respondents was falling behind on rent or mortgage payments. In fact, twice the number of African American respondents (20 percent) and more than one and half times the number of Hispanic respondents (16 percent) reported this concern compared to white respondents (10 percent).

“The survey also shows that more education is needed around the mortgage finance process, particularly to ensure more buyers understand that low down payment mortgage options are widely available,” said Johnson.

USMI’s survey found that up to 45 percent of all respondents mistakenly believe that you need a down payment of 20 percent or more to qualify for a home purchase. Another 30 percent indicated that they do not know about down payment requirements. In truth, you can qualify with a down payment as low as 3 percent. The survey also asked respondents about the role of mortgage insurance. According to survey respondents, the top reasons for MI are it “levels the playing field” and “increases lower-income families’ access to homeownership.” A majority of respondents also said it was important to have access to low down payment loans through both the conventional and government-backed markets, such as the Federal Housing Administration (FHA).

USMI members support sensible regulatory and legislative reforms to remove barriers to homeownership, and they promote an equitable and sustainable housing finance system backed by private capital. In collaboration with more than 100 organizations and individuals involved in the Black Homeownership Collaborative, USMI also supports policies that promote equity and work to increase homeownership rates among Black Americans.

ClearPath Strategies fielded USMI’s 2021 National Homeownership Market Survey of 1,000 adults in the U.S. It was commissioned online April 13-21. Quotas were set to ensure a cross sample of age, gender, race, region, and education as well as homeowners, first-time homebuyers, and prospective homebuyers. The purpose was to understand the perceptions around homeownership, the mortgage process, and the challenges people face when trying to purchase a home.

The complete findings from USMI’s national survey are available here.

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org

Press Release: New Report Shows Home Loans Backed by Private Mortgage Insurance Increased 53 Percent in 2020, Allowing More Borrowers to Access Homeownership Three Times Sooner

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Texas, California, Florida, Illinois, and Michigan among top states for mortgage financing with private MI

WASHINGTON — U.S. Mortgage Insurers (USMI), the association representing the nation’s leading private mortgage insurance (MI) companies, today released its annual report on mortgage financing supported by private MI at the national and state levels. The report finds that home loans backed by private MI increased 53 percent in 2020, a record-setting year for the nearly 65-year-old industry, with more than 2 million borrowers securing mortgage financing. Meanwhile, the report finds that saving for a 20 percent down payment could take potential homebuyers 21 years — three times the length of time it could take to save a 5 percent down payment. Texas, California, Florida, Illinois, and Michigan were the top five states for mortgage financing with private MI.

“Access to low down payment loans was more important than ever this past year as many homebuyers weighed other economic concerns during the pandemic. Mortgage insurance levels the playing field and provides lower- and middle-income households with access to mortgage credit, and the more than 2 million borrowers served this past year reached a new milestone for our industry,” said Lindsey Johnson, President of USMI.

Private MI has enabled over 35 million people access to affordable, low down payment mortgages, serving as a bridge for homebuyers to qualify for home financing despite putting less than 20 percent down. The latest USMI report examines the number of borrowers served, the percentage of borrowers who were first-time homebuyers, average loan amounts, and average FICO credit scores. USMI also calculates the number of years to save 20 percent versus 5 percent down payments for each state plus the District of Columbia.

Key findings from the report include:

  • It could take 21 years on average for a household earning the national median income of $68,703 to save for a 20 percent down payment (plus closing costs), for a $299,900 single-family home, the national median sales price.
  • The wait time decreases to seven years with a 5 percent down payment insured mortgage — a nearly 67 percent shorter wait time at the national level.
  • In 2020, the number of homeowners who qualified for a mortgage because of private MI reached over 2 million.
  • Nearly 60 percent of purchase mortgages went to first-time homebuyers, and more than 40 percent had annual incomes below $75,000. The average loan amount purchased or refinanced with private MI was $289,482.
  • The private MI industry supported $600 billion in mortgage originations in 2020. Approximately 65 percent was for new purchases while 35 percent was for refinanced loans, resulting in approximately $1.3 trillion in outstanding mortgages with active private MI coverage at year’s end.

The below table shows the top five states in which private MI was used by borrowers to purchase or refinance homes in 2020.

State Number of Borrowers Helped with Private MI First-Time Homebuyers
Texas 164,737 58 percent
California 160,103 70 percent
Florida 130,800 55 percent
Illinois 93,976 64 percent
Michigan 72,646 59 percent

Throughout 2020, the private MI industry worked closely with federal policymakers, industry groups, and consumer organizations to support homeowners experiencing financial hardships due to the COVID-19 pandemic. The industry updated its guides and processes to align with the policies of the Federal Housing Finance Agency (FHFA) and government-sponsored enterprises’ (GSEs), Fannie Mae and Freddie Mac, to implement nationwide forbearance programs.

Loans backed by private MI provide protection against mortgage credit risk and are structured to protect the GSEs in the conventional mortgage market. Private MI has proven to be a reliable method for shielding the GSEs, having paid nearly $60 billion in claims since the 2008 financial crisis and housing market downturn.

The complete report is available here, along with fact sheets for all 50 states and the District of Columbia.


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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org

Statement: HUD’s Decision to Maintain Current Pricing of FHA Mortgage Insurance Premiums

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WASHINGTON—Lindsey Johnson, President of U.S. Mortgage Insurers (USMI), released the following statement on the announcement by U.S. Department of Housing and Urban Development (HUD) Secretary Marcia Fudge that the Federal Housing Administration (FHA) will maintain its current pricing of mortgage insurance premiums (MIP) due to the agency’s high level of serious delinquency rates, and the need to continue focusing on helping the tens of millions of families impacted by the COVID-19 pandemic:

“USMI is encouraged by HUD’s continued support of borrowers impacted by the pandemic, and its focus to ensure an equitable recovery for FHA borrowers. FHA is a critical resource for borrowers to attain homeownership through FHA-backed loans—especially for borrowers who may not have access through the conventional market. Despite unprecedented challenges derived by the COVID-19 pandemic, last year saw one of the largest mortgage origination volumes since 2006. Secretary Fudge’s decision to maintain the current pricing on FHA’s mortgage insurance premiums is prudent policy and means that borrowers will continue to have access to affordable mortgage credit during a time when mortgage rates are at historic lows. This enables the FHA to better manage the financial challenges that have arisen due to the pandemic and ensure taxpayers are safeguarded from unnecessary credit risk.

“The private MI industry has the capacity and the desire to help even more families become homeowners through the conventional market. It looks forward to working with Secretary Fudge and the HUD team, as well as other policymakers and stakeholders, in support of clear, consistent, and coordinated housing finance policies that best serve all home-ready consumers and protect taxpayers from exposure to mortgage-related losses.”

In early 2021, USMI sent a letter to then HUD Secretary-designate Hon. Fudge, outlining concerns with lowering the FHA premiums too quickly and aggressively. The letter also emphasized the importance of housing policies that promote affordable and sustainable access to mortgage finance credit.

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org

Press Release: Private Mortgage Insurers Helped Over 2 Million Low Down Payment Borrowers in 2020

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Industry supported $600 billion in mortgage originations for new home purchases and refinance loans  

WASHINGTON — U.S. Mortgage Insurers (USMI), the association representing the nation’s leading private mortgage insurance (MI) companies, today announced the industry helped over 2 million low down payment borrowers secure mortgage financing in 2020, a 53 percent increase from the previous year, according to data from the government sponsored enterprises (GSEs). The industry also supported $600 billion in mortgage originations, according to public filings. Approximately 65 percent of this volume was for new purchases while 35 percent was for refinanced loans. This resulted in nearly $1.3 trillion in outstanding mortgages with active private MI coverage at year’s end, underscoring the industry’s critical role as serving as the first layer of protection against credit risk in the conventional mortgage market backed by the GSEs.

“Despite the unprecedented challenges presented by the COVID-19 pandemic, conventional loans backed by private MI continued to make the dream of homeownership a reality for millions of low down payment borrowers,” said Lindsey Johnson, President of USMI. “The record-high volume in 2020 means that more families were able to become homeowners and existing homeowners were able to reduce their monthly mortgage payments by taking advantage of historically low refinance rates.”

Johnson recently discussed the record volume in the private MI market with Claudia Merkle, CEO of National MI, a USMI member. In the interview, Merkle noted two key factors that contributed to the strong production. “First, there are more and more first-time homebuyers coming into the market. They have good credit but struggle to put 20 percent down on their first house. Private MI is a great fit for them,” said Merkle. “A second factor is attributed to low interest rates, which helped fuel the strong mortgage market momentum in 2020, for both the purchase segment and also for refinances.”

USMI members worked closely with federal policymakers, industry groups, and consumer organizations to support homeowners experiencing financial hardship due to the COVID-19 pandemic. The industry updated its guides and processes to align with the Federal Housing Finance Agency (FHFA) and the GSEs’ policies to implement nationwide forbearance programs.

“The private MI industry was able to serve as a source of strength through the COVID-19 pandemic and support a record number of borrowers because of the enhancements made by the industry—including increased capital and operational requirements,” said Johnson. “All USMI members were well-capitalized prior to the pandemic and continued to raise capital in the debt and equity markets throughout 2020 in order to scale up for increased volume.” 

At the end of 2020, USMI members held more than $6.3 billion in excess of capital requirements set by the GSEs. This furthered the private MI industry’s ability to support lenders and borrowers over the past year while operating in a unique and unpredictable market.  

The MI industry has enabled more than 35 million people to access affordable, low down payment mortgages in its nearly 65-year history. In 2020, nearly 60 percent of purchase loans backed by MI went to first-time homebuyers, over 40 percent went to borrowers with incomes below $75,000, and the average loan amount with MI was approximately $290,000.  

“This data underscores the point that the private MI industry serves a key demographic of low down payment borrowers,” Johnson added. “But the COVID-19 pandemic has further highlighted the significant racial and economic disparities in the U.S. housing market, as well as the need to increase access to affordable mortgage options. We have called on regulators and lawmakers to advance policies that promote equity by ensuring that homeownership is an achievable financial goal for all Americans.” 

In early 2021, USMI sent a letter to Rep. Marcia Fudge,  then the nominee to lead the U.S. Department of Housing and Urban Development. The association also joined with several industry groups in sending letters to President Biden and congressional leadership to emphasize the importance of COVID-19 relief for homeowners and housing policies that promote affordable and sustainable access to mortgage finance credit. Further details on the role of private MI in the mortgage market can be found here. 

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

Statement: Bipartisan Senate Confirmation of Marcia Fudge as HUD Secretary

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WASHINGTON — Lindsey Johnson, President of U.S. Mortgage Insurers (USMI), issued the following statement on the confirmation of Marcia Fudge by the United States Senate to serve as Secretary of the U.S. Department of Housing and Urban Development (HUD):

“In HUD Secretary Marcia Fudge, America gains a housing advocate with proven leadership and an accomplished record while serving in Congress and supporting investments in housing programs and community development. Her bipartisan confirmation comes at a critical time as many homeowners, renters, and residents of housing supported by HUD continue to experience hardships due to the COVID-19 pandemic. To strengthen the housing finance system, it is critical for federal policymakers and the industry to collaborate on policies that balance prudent risk management and access to mortgage credit. USMI and our member companies look forward to working with Secretary Fudge on making home financing more affordable, advancing fair housing, and ensuring that the government and American taxpayers are appropriately shielded from mortgage-related credit risks.

“For more than 60 years, the private mortgage insurance industry and Federal Housing Administration have played complementary roles, and we welcome the opportunity to work with Secretary Fudge to best serve borrowers and responsibly facilitate access to homeownership.”

On January 27, USMI sent Secretary Fudge a letter outlining several policies HUD should consider to ensure it is effectively promoting sustainable, affordable, and diverse homeownership.

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

Press Release: Private Mortgage Insurers Support Federal Housing Finance Agency Proposed Rule for GSE New Products and Activities

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USMI Applauds the Proposed Enhanced Transparency, Oversight, and Review and Encourages Rule Application to All Current Pilot Programs

WASHINGTON — U.S. Mortgage Insurers (USMI), the association representing the nation’s leading private mortgage insurance (MI) companies, submitted its comment letter to the Federal Housing Finance Agency (FHFA) on its Notice of Proposed Rulemaking for New Enterprise Products and Activities, which seeks to replace the 2009 Interim Final Rule that established a process for the government sponsored enterprises (“GSEs” or “Enterprises”) to obtain prior approval for new products and provide notice for new activities.

“USMI is encouraged to see FHFA following its statutory responsibility to establish a much more transparent and appropriate process for considering and approving new GSE products and activities,” said Lindsey Johnson, President of USMI. “The Interim Rule was adopted after the 2008 financial crisis, and as the GSEs continued to play an important and even greater role in the housing market during conservatorship, they at times expanded into new activities that are outside of the secondary market, compete in areas already well-served by the primary market, and not consistent with their mission.”

In its comment letter, USMI welcomes the increased transparency outlined in the proposed rule and supports the inclusion of “pilots” in the criteria for identifying and assessing new activities and products at the GSEs. Considering that numerous prior pilots were developed without meaningful input and analysis from industry stakeholders, USMI believes it is important that the FHFA close the loopholes that could be used again to circumvent the objectives of the proposed framework. USMI urges the FHFA to direct the GSEs to halt all current pilots and, following the implementation of a final rule, require them to submit Notices of New Activity should they want to continue offering such products or programs.

USMI also highlights in its letter the importance of the approval framework ensuring that innovations at the GSEs do not disintermediate private capital and that new activities and products operate in a manner that is within the scope of the secondary market functions set forth in their congressional charters. USMI recommends that the proposed rule be revised to provide additional clarity for the FHFA’s assessment criteria for new activities and products at the GSEs, specifically:

  • The degree to which private market participants are meeting or could meet the needs of the market and consumers, and whether the new activity or product would disintermediate non-GSE market participants;
  • Whether the new activity or product would rely on limited or broad participation by market participants;
  • How certain market participants will be selected over others, whether the activity or product will be made available to other market participants on similar terms, and whether other participants would be harmed by engagement in the activity or product; and
  • Whether the new activity or product would present a conflict of interest for the GSEs, especially where anti-competitive concerns may be present.

“This rule is sound public policy, as it will enhance transparency and provide for the appropriate review of new GSE products and activities to best serve the housing finance system and ensure that government and taxpayers avoid unnecessary new risk,” continued Johnson. “It is imperative that the FHFA continue to establish and enhance its oversight of the GSEs, and this rule is a critical step to that end.”

USMI’s full comments on the FHFA’s proposed rule can be found here.

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

Statement: Federal Housing Administration FY 2020 Annual Report to Congress

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WASHINGTON— Lindsey Johnson, President of the U.S. Mortgage Insurers (USMI), released the following statement on the Federal Housing Administration’s (FHA) release of its Fiscal Year 2020 Annual Report to Congress on the financial status of the Mutual Mortgage Insurance Fund (MMIF):

“Today’s report shows that the MMIF’s combined capital ratio stands at 6.10 percent, up from 4.84 percent last year, well above the statutory requirement of 2 percent. We applaud the FHA’s steadfast commitment to improving the fiscal health of the fund especially during these challenging times. The FHA continues to play an important role in the housing finance system, and we commend its ongoing collaboration with industry efforts to stabilize the market amidst the COVID-19 pandemic.

“The FHA is a vital part of the housing finance system and it must continue to focus on enhancing its financial strength to best serve the borrowers who need it the most. This is especially important for the FHA in a post-pandemic environment to ensure the agency does not unnecessarily expose taxpayers to undue mortgage credit risk. While some have called for the FHA to reduce its mortgage insurance premiums, the report makes it clear that this is unnecessary and imprudent at this time as consumers continue to have access to low cost mortgage credit. A reduction would diminish the MMIF’s ability to withstand potential stress caused by the economic fallout from the pandemic, evidenced in the nearly 11.6 percent of FHA-insured mortgages that are classified as seriously delinquent. Further, calls to end the premiums for the life of FHA loans are just a veiled way of reducing premiums. Such a move would jeopardize FHA’s ability to serve the borrowers who rely on its insurance today, and borrowers in the future who may need FHA to access homeownership. Now, more than ever, is the time for the FHA to sustain its financial health and focus on its core mission — to serve borrowers the conventional market is unable to adequately serve.

“USMI and our member companies look forward to continuing to work with FHA and Congress to foster a robust housing finance system that meets the needs of low down payment borrowers while protecting taxpayers. To this end, it is essential that federal policymakers advance a coordinated housing policy to best balance consumers’ access to affordable mortgage finance and prudent management of mortgage credit risk.”

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org.

Press Release: New Report, “Private Mortgage Insurance: Stronger and More Resilient”

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Over 10 Years of Reforms and Continued Evolution Make Private Mortgage Insurers Stronger and More Resilient

Industry has facilitated affordable, low down payment mortgages for over 33 million households, contributing to a more stable housing finance market

WASHINGTON — U.S. Mortgage Insurers (USMI), the association representing the nation’s leading private mortgage insurance (MI) companies, today released a report that highlights the many regulatory and industry-led reforms taken since the 2008 financial crisis to improve and strengthen the role of private MI in the nation’s housing finance system. The report, “Private Mortgage Insurance: Stronger and More Resilient,” analyzes the various steps the industry and regulators undertook and continue to take to ensure sustainable mortgage credit through all market cycles and to better serve low down payment borrowers in the conventional market, especially during critical times such as the present.
 
“Though private mortgage insurers have been a crucial part of the housing finance system for more than 60 years, this is definitely ‘not your father’s’ MI industry. Enhanced capital and operational standards, as well as increased active management of mortgage credit risk, including through the distribution of credit risk to the global reinsurance and capital markets,  has put the industry in a stronger position,” said Lindsey Johnson, President of USMI. “These enhancements will enable the industry to be a more stabilizing force through different housing cycles — including the current COVID-19 crisis — which greatly benefits the GSEs and taxpayers and enhances the conventional mortgage finance system.”  
 
The report also highlights the steps the industry has taken since the beginning of the pandemic to support the federal government foreclosure prevention programs, including the announcements made by Fannie Mae and Freddie Mac regarding forbearance programs and other mortgage relief available to support borrowers impacted by COVID-19. USMI members have focused their efforts on helping borrowers remain in their homes by supporting their lender customers during these challenging times.
 
Among the enhancements to the industry in the last several years, the report outlines and analyzes the following:

  • Private Mortgage Insurer Eligibility Requirements (PMIERs) – Adopted in 2015 and updated in 2018 and 2020, PMIERs nearly doubled the amount of capital each mortgage insurer is required to hold. USMI members collectively hold more than $5.1 billion in excess of these requirements.
  • New Master Policy – Updated terms and conditions from mortgage insurers for lenders, which provide lenders with greater clarity pertaining to coverage.
  • Rescission Relief Principles – First published in 2013 and updated in 2017, these principles allow MIs to offer day-one certainty to lenders of coverage, including automatic relief after 36 timely payments.
  • MI Credit Risk Transfer (MI-CRT) Structures – Private MI companies have transferred $41.4 billion in risk on over $1.8 trillion of insurance- in-force (IIF) since 2015—through both reinsurance and insurance-linked notes.

Through the programmatic execution of MI-CRT transactions, the industry continues to transition the business into an aggregate-manage and distribute model for mortgage credit risk.  The implementation and expansion of MI-CRT programs have demonstrated the industry’s ability to tap multiple sources of capital to support new business and actively manage and distribute risk. 
 
Since 1957, the MI industry has served the U.S. government and taxpayers as an effective and resilient form of private capital, standing as the first layer of protection against risk and mortgage defaults. Importantly, MI has enabled affordable, low down payment homeownership for more than 33 million people. In 2019 alone, more than 1.3 million borrowers purchased or refinanced a loan with private MI, accounting for nearly $385 billion in new mortgages.  

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org

Press Release: Comment Letter to CFPB For Proposed Rule on the General Qualified Mortgage Definition

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WASHINGTON — U.S. Mortgage Insurers (USMI), the association representing the nation’s leading private mortgage insurance (MI) companies, submitted its comment letter to the Consumer Financial Protection Bureau (CFPB or Bureau) for its proposed rule on the General Qualified Mortgage (QM) Definition under the Truth in Lending Act (Regulation Z).

“While the CFPB is undertaking a thoughtful process to update the General QM definition, USMI urges the Bureau to strike a proper balance between prudent and transparent underwriting standards, and access to affordable and sustainable mortgage finance credit for home-ready borrowers,” said Lindsey Johnson, President of USMI. “Changes to the QM definition will broadly inform standards and practices across the mortgage market, but the currently proposed rule could limit access to the conventional market for the very borrowers that have traditionally been underserved.”

To ensure the QM definition does not inadvertently limit access to credit for home-ready borrowers, and particularly minority borrowers, USMI recommends that the QM Safe Harbor should be set at 200 basis points (bps) above the Average Prime Offer Rate (APOR). USMI states that this modification to the proposed rule would create a level playing field for the QM standard across the conventional and government mortgage markets, adding that historical delinquency data demonstrates that conventional mortgages with rate spreads between 150 bps and 200 bps are prudently underwritten and sustainable loans that have performed well.

USMI highlights that “[a]ccording to 2019 Home Mortgage Disclosure Act (HMDA) data for conventional low down payment purchase mortgages (>80 percent loan-to-value ratio), Black and Hispanic borrowers were twice as likely as White borrowers to have mortgages with annual percentage rates in excess of the APOR plus 150 bps Safe Harbor spread. Under the proposed rule, many of the borrowers who are above the 150 bps threshold will be left only with the option of a Federal Housing Administration (FHA) loan, which means they have significantly fewer competitive choices in terms of product offerings and loans.”

Further, USMI agrees with the Bureau’s assessment that a hard 43 percent debt-to-income (DTI) ratio cap would be the most harmful option for the General QM definition because it would severely limit access to credit in the conventional market. Consistent with its September 2019 comment letter in response to the CFPB’s Advance Notice of Proposed Rule (ANPR) on the QM Definition, USMI continues to believe that the best approach to a General QM definition would be a standard that includes a higher DTI threshold with specified compensating factors.

In its comments, USMI advises the CFPB to preserve robust and measurable underwriting standards and practices as part of the requirements for “consider and verify” that have been proven to balance access to credit and prudent mortgage underwriting standards. With the elimination of reliance on a DTI cap and the introduction of a “consider and verify” standard for mortgage underwriting, it is critical that the CFPB identify specific requirements or best practices to be used by lenders to qualify for the compliance safe harbor.

Other recommendations to the CFPB include: working closely with federal regulators to implement a transparent and coordinated housing policy that promotes access to credit and prudent mortgage underwriting and creates a level playing field; and reconsidering its approach to adjustable-rate mortgages (ARMs) by amending the NPR to exclude 5-year ARM products from the proposed treatment of short-reset ARMs, as data demonstrates that ≥5-year ARM performance is in line with, or better than, >20-year fixed rate mortgages.

Finally, USMI urges the CFPB to provide sufficient time for a smooth transition from the temporary QM category (known as the government sponsored enterprises or “GSE Patch”) to the new General QM definition. This is particularly important given the extensive and undetermined scope of COVID-19 as the financial services industry appropriately focuses resources on responding to the economic and health fallout from the pandemic.

USMI writes, “[d]epending on the complexity of the finalized revisions to the General QM definition, the significance of the penalties for a violation of the [ability to repay]/QM Rule, and the large number of mortgage industry participants that will need to update their operations and systems, USMI recommends that the Bureau set the sunset date for the GSE Patch to be at least six months after the effective date of the general QM definition final rule. This would allow lenders to use either the GSE Patch or the new General QM definition during the mortgage underwriting process.”

USMI’s full comments on the CFPB’s proposed General QM Definition can be found here; its comment letter to the Bureau on the GSE patch extension can be found here; the 2019 comment letter to the CFPB’s Advance NPR can be found here; and its blog on why the Safe Harbor threshold should be increased can be found here.

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U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership. Learn more at www.usmi.org