With this version, if a borrower isn't yet in default the lender can refinance up to 105% LTV. If a borrower is in default the lender can lend up to 96.5% LTV if they keep 31/43 front/back debt to income ratios. And if a borrower is in default and the lender wants to push the ratios to 38/50 then the max LTV becomes 90%. Readers may remember the previous version required a max LTV of 90% regardless of scenario. I think the "borrower not in default" version will be very popular as it cleans up the banks books very nicely and turns toxic sludge into a loan in which no capital needs to be held against it since it is now guaranteed by the US government.
The up front mortgage insurance premiums (MIP) was 3% in the previous version and now it becomes 2%. The annual premium was 1.5% in the previous version and it is reduced to .75%. These premiums are what protects the taxpayers from having to bail out the FHA. Obviously the banks would want them as low as possible so that the borrowers are paying the banks more money rather than covering the FHA from losses. It looks like the banks did pretty good (from their point of view) in getting them reduced. Anyone thinking that the FHA won't be bailed out is delusional. It is simply a matter of when.
I went over what I thought the effects of this new H4H plan would be back in a post (more accurate: Rant) in early September that readers can read here:
"The Fed can tremendously influence rates, however temporarily, they can bring down rates to even lower levels so the qualification for H4H is easier and the banks can put as many loans in H4H in as little time as possible. While there may be a hit to capital to the banks they magically turn a non-performing loan into a performing loan which carries zero risk and they wouldn't have to withhold any capital or increase loan loss reserves against it."
I think that the underwriting details are sufficiently "loose" that the prediction could hold true. The banks will have to take principal write downs but I would bet for many non-performing loans the ability to refinance to FHA would actually free up capital. I would expect transaction volumes to drop even further as even less motivated supply comes on market. Fewer short sales due to H4H, fewer foreclosures due to HAMP. There will clearly be fewer people making their living in construction, real estate agents, and in the lending field as a result. Asset price "stability" will be maintained at a huge cost to taxpayers and the real estate industry but it is public policy that prices must be maintained. Allowing a massive credit bubble in the name of "free markets" but then socializing the losses AND having a policy that deflation will not be tolerated makes some pretty wacky (i.e. stupid) ideas suddenly sound logical to those desperate to "do something".
I wonder if the politicians have heard, or care about, adverse selection. I guarantee the banks are well versed and will act accordingly. The worst of the worst will get refinanced and the "good" loans won't be so the banks can maximize profit.