Oregonian Hardest Hit Housing Program Story in Sunday Paper; What's New.

In case great weather and Mother's day diverted your attention away from the "O", above the fold Sunday story on Oregon Hardest Hit Housing Program is HERE. 

New reporting not covered by my earlier posts about program: 

1. Story says that $1.75 million in payments were made to 242 homeowners without proper documentation and cannot be recovered : "Officials later determined that some of their new customers actually were not eligible. The state terminated 242 homeowners from the program. But by that time, the state had extended them more than $1.75 million in assistance. State officials decided they would make no effort to retrieve the money. There was little doubt the applicants were in financial straits sufficient to qualify for the program. But they lacked documentation necessary to prove it, said agency spokeswoman Karen Tolvstad. For that reason, the state felt it was "inappropriate" to pursue the money, Tolvstad said, adding that U.S. Treasury officials agreed."

2. Story has some details about October 2011 report from Treasury on Oregon Program, saying it "dinged Oregon's underwriting as sub-par on several fronts. It also noted the agency wasn't doing criminal background checks on employees and lacked a process to report fraud to Treasury. "

3.  Says that Further Development has received $750,000 for 11 deals in pilot loan refinancing program. Reporting also appears to indicate that state will be looking to change the flat monthly fee structure in the Further contract, quoting Director Van Vliet: "If they [Further] can make this work, it could be huge. But I don't have the luxury of paying a flat fee." [My earlier post with Further contract is HERE].

4. There is an April 6th letter from Treasury to Oregon indicating that Treasury says there is more work to be done : "McArdle said Oregon's loan underwriting is still not up to par. State staffers persist in not determining that applicants meet all eligibility criteria". 

Originally created and posted on the Oregon Housing Blog.

New GAO Report on TARP Costs Says Costs Down, Big CBO/Treasury Differences Exist about Housing Costs.

GAO report is HERE.  From the report: 

 In 2009, the Congressional Budget Office (CBO) estimated that TARP could cost $356 billion. However, CBO’s most recent estimate, using November 2011 data, is approximately $34 billion.

Treasury’s fiscal year 2011 financial statement, audited by GAO, reported that TARP would cost around $70 billion as of September 30, 2011, a decrease from about $78 billion estimated as of September 2010.

…. program participation assumptions for TARP-funded housing programs explain the large difference between the CBO and Treasury cost estimates.

Treasury assumed that all of the $45.6 billion allocated to TARP housing programs would be utilized and, as a result, estimated that they would cost $45.6 billion.

Conversely, CBO expected lower participation rates for the housing programs, resulting in a cost estimate of $13 billion as of November 2011

If you do the math you will see that:

1. Housing program costs represent 38% of projected TARP costs according to CBO and 65% according to Treasury.  
2. Treasury's estimated TARP housing program cost is 251% higher than the estimated CBO TARP housing program costs.

Originally created and posted on the Oregon Housing Blog.

The Case for Build America Bonds.

Treasury PR is HERE, says they saved state and local govs $20 billion in borrowing costs. 

Originally created and posted on the Oregon Housing Blog.

Treasury Asking for Industry, Consumer Feedback on Prototypes That CombineTwo Mortgage Disclosure Forms.

Treasury PR is HERE. 

Prototypes of disclosures can be found HERE; feedback sought from consumers and industry on differing versions.

PR announces the :

..Know Before You Owe project, an effort to combine two federally required mortgage disclosures into a single, simpler form that makes the costs and risks of the loan clear and allows consumers to comparison shop for the best offer.

Originally created and posted on the Oregon Housing Blog.

Risk Retention Rule Summary.

Prior to publication tomorrow of proposed rule, the summary HERE is from American Banker.

Originally created and posted on the Oregon Housing Blog.

Treasury Says Housing Programs Represent 90% of Projected TARP Cost.

In advance of a regular monthly statutorily required report on TARP progress the US Treasury published a PR piece detailing their positive spin on TARP. That report is HERE.

Without drinking all of the Kool-Aid, I think it IS fair to say that total TARP costs WILL be far, far below the $700 Billion initial TARP authorization.

On PDF page 8 of their report the Administration says the total projected TARP cost is $51 billion. Treasury says that $46 billion of that cost will be for housing programs including MHA programs like HAMP; the HFA Hardest Hit fund; and the FHA Short Sales program.

That means that Treasury is currently projecting that housing programs will represent 90% of the TOTAL TARP COST, a projection that will come as a surprise to most. 

Note also that housing costs for HUD NSP, Emergency Assistance, Recovery Act housing programs, homeowners tax credits AND the GSE bailout are NOT included in the $46 billion projected TARP housing costs.

Originally created and posted on the Oregon Housing Blog.

Correction: Hardest Hit Funding in 19 States Now Up to $7.6 Billion; That's 22%/ $1.3 Billion More than HUD CDBG, HOME, ESG,and HOPWA Funding in ALL 50 States and Territories.

Correction:
Corrected text below to correctly refer to order and content of 3 tables in my updated PDF file. PDF file did not change.
-----------

Readers may recall my earlier blog post after the second round of Hardest Hit funding included a table HERE that compared Hardest Hit funding to funding levels in each state for 4 major HUD programs (CDBG, HOME, ESG, and HOPWA). 
  
That initial analysis showed that $2.1 Billion in Hardest Hit funding for these 10 states was $112 million/6% more than their total funding for these 4 HUD programs.

On Sept 29th Treasury allocated an additional $3.5 Billion in Hardest Hit funding, so this is an UPDATE showing the distribution of those funds as well the distribution of an additional $2 Billion allocated earlier in September.  


I have combined my analysis in a single PDF file with three tables HERE. (Table 1 is two pages, other two tables one page each).

1. The first table is a is an update to my earlier table comparing Hardest Hit funding in 19 states to their funding for the 4 major HUD programs. (Legal sized to fit all columns).
2. The second table is a recap of all Hardest Hit funding to date, NOW $7.6 Billion. It shows funding by state and date. 
3. The third table is a new comparison that ranks how much each state received in Hardest Hit funds per homeowner with a mortgage.

Observations

1. Prior Analysis : 10 State Hardest Hit Funding Exceeded Program Funding for 4 Major HUD Programs by 6%, and Oregon HH Funding Exceeded HUD Funding for 4 Programs by 37%,

My earlier post included a table HERE that compared Hardest Hit funding to all HUD funding in each state for four major HUD programs:  CDBG, HOME, ESG, and HOPWA.  At that point $2.1 Billion in Hardest Hit funding had been allocated.

2. Updated Analysis (Table 1): 19 State Hardest Hit Funding Exceeds HUD 4 Program Funding by 149%, and Oregon Exceeds HUD Funding for 4 Programs by 242%.  

19 state Hardest Hit Allocation of $7.6 Billion Also Exceeds 50 State and Territory Funding for 4 Major HUD Programs ($6,221,594,435) by $1.3 Billion/22%.

3. (Table 2) The last round of funding on Sept 29th added $3.5 billion to Hardest Hit funding, with all 19 states receiving funding. 

Hardest Hit TARP funding has increased by $6.5 Billion/407% from the initial 5 state allocation of $1.1 Billion and $5.5 Billion/262% from the initial 10 state allocation of $2.1 billion.

4. Hardest Hit Funding Per Homeowner With a Mortgage: At $336 Oregon Ranks 6th Highest.

The third table compares total Hardest Hit funding per state to the number of owner occupied households WITH a mortgage in each state using data from the newly released 2009 American Community Survey.  In that table you will see that:

1. The average Hardest Hit funding per homeowner with a mortgage in the 19 states receiving Hardest Hit funding was $283.
2. Oregon's Hardest Hit funding per homeowner with a mortgage is the 6th highest, at $336 per household. 
3. Nevada had the highest Hardest Hit funding per homeowner with a mortgage at $441.
4. Indiana had the lowest Hardest Hit funding per homeowner with a mortgage at $181. 
5. Since only a PORTION of homeowners with a mortgage have a problem the ACTUAL amount per homeowner in distress on their mortgage is much higher than the amounts shown above. If 10% of homeowners with a mortgage are in distress the per homeowner amount available would be 10 times the amounts shown above; if distressed % is 5%, amount would be 20 times higher than shown, etc.  

NOTE: As of Saturday, Treasury has yet to issue a press release on the latest round of Hardest Hit funding, so for now this is likely the ONLY place where total Hardest Hit funding for ALL states and ALL rounds can be found--I dug the data out of TARP reports found on the Treasury Financial Stability website. 

 Originally created and posted on the Oregon Housing Blog

Treasury Issues Servicer Guidance on Interaction of Hardest Hit Program with HAMP.

Announcement is HERE: direct link to 9 page guidance PDF (Supplemental Directive 10-07) is HERE.

Originally created and posted on the Oregon Housing Blog.

Administration Ramping Up Housing PR.

Interesting summary of these efforts in this CNBC Real Estate blog post HERE. (Not mentioned is likely future PR around $14 billion roll out of FHA refinancing program for underwater borrowers; my prior post HERE).

Originally created and posted on the Oregon Housing Blog.

Treasury Approves/Posts 1st Round Hardest Hit Housing Plans.

PR is HERE. 

As approved individual plans are HERE on Treasury website; I have consolidated them into one PDF document, posted in new link in right pane, Hardest Hit Plans, as APPROVED by Treasury. (Interesting that approved plans are about 30 pages each, when submissions were close to 50 pages each).

My prior posting of plans as submitted to Treasury are in one PDF document, sans Nevada, HERE. 

Originally created and posted on the Oregon Housing Blog.

Oregon Perm HAMP Loan Mod Inventory Continues Up, Seems Likely to Exceed Trial Loan Inventory by End of June.

New national HAMP status report as of end of May from Treasury is HERE. 

I have broken out HAMP loan modification data for US, Oregon, and Oregon metro areas in tables I constructed HERE. 

Some Oregon observations as of the end of May: 

1. Oregon inventory of active trial loan modifications continue to shrink, down by 43% since start of year. 
2. Oregon inventory of active permanent loan modifications continues to increase, reaching 3,918, an increase of 348% since January 1.This is somewhat less than the national rate of permanent loan modification increase of 413%.
3. Following trend in items 1 and 2, it seems likely that Oregon inventory of permanent loan modifications will for the first time exceed inventory of trial loan modifications at the end of June. (Note that at start of year, permanent loan modification inventory was less than 1/10th the inventory of trial loan modifications)
4. Oregon permanent loan modifications increased by 499 in May, but this was down from 741 increase in April.

Originally created and posted on the Oregon Housing Blog.

New HUD-Treasury Monthly Housing Scorecard.

PR is HERE.

First scorecard is HERE. 

Originally created and posted on the Oregon Housing Blog.

Fannie Freddie Fix So Far: $160 Billion; Worse Case, $1 Trillion?

Business Week has summary of Bloomberg News story HERE.

Originally created and posted on the Oregon Housing Blog.

TARP Statute and Regulations Underlying the Hardest Hit Program.

To date guidance from Treasury to state HFA's for the Hardest Hit program has been in the form of administrative guidance and FAQ's.  In my prior HUD career "administrative guidance" would be equivalent to "HUD handbooks" that had a different legal weight than regulations that had undergone a more rigorous public rule making process.

For ongoing use in the Hardest Hit Program I thought it would be useful to provide links to the actual TARP statute and the TARP regulations from Treasury:

PL 110-343 , Emergency Economic Stabilization Act of 2008.
31 CFR Part 31, Treasury regulations for the TARP program.

Originally created and posted on the Oregon Housing Blog.

Arizona Goes the Summary Route with Their Hardest Hit Plan Post; California Claims They CAN'T Disclose How They Plan to Spend $700 Million from TARP.

Arizona Goes the 4 Page Summary Route: Arizona's 4 page summary of how they plan on spending $125.1 million HERE is one page longer than Michigan's web posting.

California: We Can't Disclose How We Plan on Spending $700 Million in TARP Funds.
This will come as a big surprise to Florida's HFA (who has published their plan on the web) but the California Housing Finance Agency is CLAIMING they CANNOT disclose the plan because (wait for it) Treasury won't let them. This is what the California HFA has said on their website:

"we have been informed by the U.S. Treasury that the Hardest Hit Program proposals are to be treated as confidential, and at this time, we do not have a timeframe for when Treasury will provide us with a response to our proposal. These documents are exempt from disclosure under application provision of the Freedom of Information Act. The California Public Records Act specifically exempts such federally exempt documents from disclosure"

I don't know how many of you listen to Car Talk on NPR, but to quote both Click and Clack (Tom and Ray) this feels totally B-O-G-U-S to me and I sure hope someone in California challenges this assertion.

Nevada: I don't see anything yet.

Originally created and posted on the Oregon Housing Blog.

Florida Posts Hardest Hit Proposal Submitted to Treasury Today, Adds Q and A's.

From their Hardest Hit web page HERE, the Florida Housing Finance Corporation has posted the plan they submitted to Treasury. This is the first actual plan posted to the web that I have found (Michigan's HFA posted a 3 page summary of their plan earlier).

The 38 page plan to spend the $418 million allocated to Florida is HERE; questions and answers about the plan are HERE.

Originally created and posted on the Oregon Housing Blog.

New Breakout of Oregon HAMP Loan Modifications by MSA.

I have constructed a new set of tables that show by Oregon MSA, all HAMP loan modification data from December 2009 through March of 2010. I think this is the first time this data has been consolidated for all months, for all Oregon MSA's.

The tables HERE allow readers to see, for each MSA, how many loan modifications have been completed each month, and the % change during that month. In addition to CHANGE data, the tables also show the inventory of loan modifications by category for each month.

The table pasted below extracted from the linked tables focuses on the CHANGE in loan modifications by category during the most recent month, March 2010.

Some observations:

• Bend, Eugene, and Medfor MSA's had about the same number of permanent loan mods in March; Salem had a few more than these MSA's.
• Corvallis had very few loan modifications during March.
• Portland's MSA data includes Clark and Skamania county in Washington state, so don't add across to get to a MSA total as that will include some loan mods in Washington state.
• This data MAY be useful in assessing Hardest Risk areas of the state, and in helping to focus on areas of the state where loan modifications are taking place. (Perhaps one day OHCS will be able to pry out of Treasury the actual loan level data used to sum up to these MSA levels--lender loan modification database includes geo identifiers down to census track level).
  

Metric	OREGON	Bend	Corvallis	Eugene-Springfield	Medford	Portland-Vancouver-Beaverton	Salem
March-Feb Trial Loan Mod Chg	(480)	(36)	6	(43)	(35)	(327)	(63)
March-Feb Permanent Loan Mod Chg	630	52	2	49	53	414	68
March-Feb TOTAL Loan Mod Chg	150	16	8	6	18	87	5
March-Feb Trial Loan Mod Chg	-5%	-4%	10%	-6%	-5%	-5%	-7%
March-Feb Permanent Loan Mod Chg	31%	23%	25%	33%	27%	29%	39%
March-Feb TOTAL Loan Mod Chg	1%	2%	11%	1%	2%	1%	0%

Originally created and posted on the Oregon Housing Blog.

Oregon HAMP March Loan Modification Data: Permanent Mods Up by 31%, Trials Down by 5%.

Last month in a post HERE, I reported big drops in Oregon total and trial loan modifications resulting from a 96% drop in TRIAL loan modifications.

The March Treasury report on HAMP has been released and it shows that Oregon total modifications went up because permanent loan modifications increased by 630 during March, an increase of 31% compared to February, slightly lower than the 35% national increase. Trial modifications continued to decline during March in Oregon, down 5% from February.

The table below shows the CHANGE in HAMP loan modifications for Oregon and US during March:

Metric	TOTAL	OREGON	% Chg, US	% Chg, Oregon
March-Feb Trial Loan Mod Chg	(54,243)	(480)	-6%	-5%
March-Feb Permanent Loan Mod Chg	59,214	630	35%	31%
March-Feb TOTAL Loan Mod Chg	4,971	150	0.5%	1%

As more permanent loan modifications are put into place, the inventory of trial loan modifications has decreased in Oregon; in March that inventory reduced by 480 loans, to 8,955 loans.

I have completed a three page set of tables HERE that includes an Oregon and US summary AND a table with loan modification data for all states from Dec 2009-March 2010. (First page is letter size, pages 2-3 are legal).

The complete Treasury March loan modification press release, which includes state tables for March, is HERE.

Originally created and posted on the Oregon Housing Blog.

Administration Seeks Public Input on Reform of the Housing Finance System; House Hearing Also.

Treasury PR is HERE. (Some public forums around country; also public comments can be submitted through Regulations.gov, I will update with link to docket once Notice is published).

House Hearing today, web page HERE.

Originally created and posted on the Oregon Housing Blog.

Hardest Hit TARP Funding Comparison: Oregon Getting 37% MORE than ALL Oregon FY 2010 CDBG, HOME, ESG, and HOPWA Funding.

Later this week I hope to do a post about the public disclosure I see in the first round of Hardest Hit funded states whose plans are due to the Treasury by COB on April 16th. I will also post a preview of what state plans are required to contain, and what therefore should be available for public comment, prior to submission to Treasury (with Oregon's expected submission date to Treasury near the end of May).

In my view this disclosure is important not only because of the importance of the intended use, not only because it is TARP money, but also because the level of funding is quite extraordinary.

I have said before that the Hardest Hit funding for Oregon is the largest housing grant in Oregon history. To provide even more perspective I thought it would be useful to compare Hardest Hit funding in ALL states to the level of funding that ALL grantees (including entitlement communities) within those states will receive this year for the four main HUD Community Development programs where funding is allocated by formula:

1. Community Development Block Grant
2. HOME
3. Emergency Shelter Grants
4. Housing for Persons with Aids

Some Observations from the Table I Put Together HERE:

• The $2.1 billion in Hardest Hit funding being received by these 10 states is $112+ million more (6% more) than the total FY 2010 grants received in these states for these four HUD grant programs.
  
• Oregon does even better. Oregon's Hardest Hit funding is 37% MORE than the total HUD FY 2010 funding in Oregon for these 4 grant programs. ($88 million/$64.3 million-1). Oregon will receive $23.6 MORE in Hardest Hit funding than all grantees in Oregon will receive from these 4 HUD grant programs ($88 million - $64.3 million).
• Somebody really likes Nevada and South Carolina. They are getting 185% and 103% more in Hardest Hit funding than their total HUD grants for these 4 programs.
  

Originally created and posted on the Oregon Housing Blog