Evaluation of FHFA’s Role in Negotiating Fannie Mae’s and Freddie Mac’s Responsibilities in Treasury’s Making Home Affordable Program

Why FHFA-OIG Did This Evaluation

In early 2009, the Federal National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie Mac) (collectively the Enterprises) began participating in the Department of the Treasury’s (Treasury’s) Making Home Affordable Program (MHA). One key MHA initiative, the Home Affordable Modification Program (HAMP), involves mortgage servicers agreeing to modify mortgage terms (e.g., lower the monthly payment) for borrowers facing imminent default or foreclosure.

The Enterprises participate in HAMP and modify loans in their portfolios. They also administer and enforce the program for other loan servicers as Treasury’s financial agents under Financial Agency Agreements (FAAs).

Questions have arisen concerning the Enterprises’ participation in MHA. Some argue that Treasury has employed the Enterprises to manage the MHA program in ways that jeopardize their financial interests and has done so without adequate consultation and coordination with the Federal Housing Finance Agency (FHFA), potentially compromising its independence as the Enterprises’ conservator and regulator.

The FHFA Office of Inspector General (FHFA-OIG) initiated this evaluation to assess the relationship between FHFA and Treasury in the context of FHFA’s oversight of Fannie Mae’s and Freddie Mac’s participation in MHA programs.

What FHFA-OIG Recommends

FHFA-OIG recommends that FHFA engage in negotiations with Treasury and the Enterprises to amend the FAAs by incorporating a specific dispute resolution process under which the parties may discuss differences that arise in the Enterprises’ administration of HAMP and establish strategies by which to resolve or mitigate them.

What FHFA-OIG Found

FHFA-OIG found no evidence that in developing and implementing MHA programs Treasury has compromised FHFA’s independence as the Enterprises’ conservator and regulator. The Emergency Economic Stabilization Act of 2008 (EESA) requires FHFA to coordinate within the federal government in developing and implementing loan modification programs such as HAMP. FHFA has supported HAMP as a means to limit the Enterprises’ credit losses by minimizing costly foreclosures. At the same time, FHFA has exhibited independence by prohibiting the Enterprises from participating in other MHA programs that it views as being inconsistent with their financial soundness.

However, FHFA did not play an active role in reviewing and negotiating Treasury’s FAAs with the Enterprises. The FAAs represented long-term commitments of significant resources at a time when there were substantial concerns about the Enterprises’ financial and operational capacity. Nevertheless, FHFA limited its review to ensuring that the Enterprises were legally authorized to enter into the FAAs and did not review their substance. As a consequence, two key terms were left undefined: the scope of the work to be performed by the Enterprises, and the terms under which they would be compensated. Significant problems developed in both of these areas almost from the beginning, requiring FHFA and the Enterprises to devote substantial time and resources to their resolution. Thus, FHFA-OIG finds that FHFA’s conservatorship interests would have been better served if FHFA had played a greater role during the negotiation and review of the FAAs.

In early 2010, Treasury, FHFA, and the Enterprises developed a new method for reviewing and approving tasks assigned to the Enterprises under the FAAs. It represents a significant improvement over the process contained in the initial FAAs. However, the lack of a specific dispute resolution process in the revised approach increases the risk that disputes among parties will not be resolved efficiently.

Full report below…

~

4closureFraud.org

~

Evaluation of FHFA’s Role in Negotiating Fannie Mae’s and Freddie Mac’s Responsibilities in Treasury’s Making Home Affordable Program