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FHA has been getting a lot of bad press lately. A former Fannie Mae executive recently testified before congress that he expects FHA will need a government bailout within the next 24-36 months. A new bill has been introduced in Congress to raise the FHA minimum down payment from 3.5% to 5%. I have read a whole bunch of articles on why FHA loans are a ticking time bomb, the new version of sub prime, and how the government should stop trying to prop up the housing market and leave financing to the private market. Are these critics right? Is FHA the next disaster in the making? Should FHA clamp down and make it tougher to buy a home?

As a mortgage lender who has worked with FHA home buyers for over 18 years, I admit that I am biased in favor of the program. But it seems to me that these critics aren’t looking at the bigger picture. The fears of an FHA collapse are all based on the idea that FHA loans are inherently risky. To an extent, they are right. FHA was set up to help low and moderate income borrowers get a chance to own a home, and it has always made low down payment loans to borrowers who might not have qualified for privately funded conventional programs. But FHA isn’t now, and never has been a sub prime program. There is no doubt that FHA defaults will rise, but with the unemployment rate high and rising, foreclosures are growing throughout all loan classes and price ranges – including Jumbo mortgages where the borrowers originally put down 20% or more for their down payments. The truth is, FHA has increased its market share because Fannie Mae and Freddie Mac (now owned by the government) have made their financing much tougher and more expensive (especially for first time home buyers) and there are almost no private lenders left. FHA’s defaults will grow, because its market share is growing, and it is now the only game in town.

Here are some things to consider the next time you hear someone ripping on FHA:

• FHA loans are not like sub prime – FHA loans are fully underwritten and the borrowers have to prove their income and assets and show that they have the ability to afford the payments. While FHA doesn’t have minimum credit score standards, all the lenders who make FHA loans now do. For most lenders you will need at least a 620 credit score, the same score that was considered an A loan in conventional financing just 2 years ago.

• A loan made today is safer than older loans – FHA loans have gone from a market share of about 2% two years ago to about 40% now. This means that there were very few FHA loans being done during the bubble years (when 0 down financing was available to anyone who could fog a mirror, good credit or bad). This means that FHA doesn’t have the big inventory of underwater loans that is the norm with conventional portfolios. Which loan has a less risk of default? A mortgage where the borrower bought at the height of the bubble with 20% down with no income verification? Or an FHA loan underwritten in today’s market, bought at current (lower) value, with income and employment fully verified? I’m going with the second scenario. Property values may fall lower, but if we are not at the bottom we are a whole lot closer to it now, which means less risk.

• Many of the FHA borrowers now would have been conventional buyers in the past – Conventional loans, those covered by Fannie Mae and Freddie Mac guidelines, used to be priced the same for all borrowers who qualified for a loan. Over the last 2 years, as loan losses mounted, these organizations not only made it more difficult to qualify for a loan, but they raised the cost of financing for many of those who do qualify. This means price hits not just for lower credit scores, but things like having less than a 25% down payment when buying a condo. Mortgage insurance guidelines are much more restrictive now, too. It now makes sense to compare FHA pricing to conventional for anyone who is putting less than 20% down, and there are a lot of FHA borrowers who could qualify for conventional if they were willing to pay more for the loan.

• FHA loan quality is higher now than at any time in recent years – FHA has tightened its requirements in several ways over the last few years. The minimum down payment has increased from 3% total investment (which used to include a combination of down payment and closing costs) to 3.5% down payment. They did away with the down payment assistance programs which allowed the seller to pay for the borrowers down payment so the borrower was coming in with no money down. The up-front mortgage insurance premium increased, which means more money goes into the reserve fund. These changes have all increased the over all loan quality, but a bigger change has been how the loans are now underwritten. A few years back, underwriting (for all loans) was loose. Now underwriters are scrutinizing files for anything that even hints at a problem. Wholesale lenders are doing the same, and FHA will cut off any company that tries to bend the rules (Taylor Bean, a large FHA lender wholesaler was cut off by FHA due to quality issues, and was out of business shortly after).

• FHA is self funded and NOT financed by the treasury – FHA doesn’t make the loans themselves, they insure loans made by private lenders according to their guidelines. The FHA program is really a mortgage insurance program. FHA gets a funding fee (currently 1.75% of the loan amount) upfront on every loan (this is usually financed into the loan amount for the borrower) as well as a monthly mortgage insurance premium. This insurance fund has worked well in the past. FHA is solvent, and has reserves of about $30 billion dollars, the highest on record. The problem isn’t that FHA is paying out too much now, but that it has grown so quickly and would be in trouble if the loans on its books turn sour. Compare this to Fannie and Freddie and all the big banks, who have already needed bailouts.

• FHA may be saving the real estate market – If FHA made it harder to get a loan, what would this do to the real estate market? I’ve heard commentators say that no one should be able to buy unless they have a 20% down payment. Saving up for a down payment is the biggest obstacle to buying a new home. Raising the cost of entry takes most of the first time home buyers, the biggest group, out of the market. Even an increase to 5% down payment would take a big group of buyers out of the market. Making it harder for first time home buyers to buy means less move up buyers. The law of supply and demand says that if you have less buyers, home prices will go down.

FHA has grown so much over the last 2 years because they are fitting a need in the market. Loan defaults aren’t caused by low down payments. Bad loans usually occur because of other factors like medical problems, divorce and the loss of a job. As long as the economy is still rocky, unemployment will be high and that means there will be more loan defaults and foreclosures coming. But that isn’t an FHA problem, this is happening with all loans. Owning your own home is a big part of the American Dream. There is a societal benefit to home ownership, too. High ownership rates stabilize neighborhoods and give people a vested interest in their community. The typical first time home buyer using FHA is young, usually in their 20s or 30s. Their earning power is still on the upswing, and they are in the early stages of their careers. I have a long list of clients who bought their first home with a low down payment, then moved up to larger more expensive homes as they built up equity (I fit that category myself). This is a different market, and no one knows what the future holds, but my guess is that the people who are buying now, are getting good bargains, and at some point the housing market will stabilize. If we make it so that only the most qualified are able to buy, it hurts everyone.

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