MHI is pleased that earlier this week, Ginnie Mae released its pooling guidelines for loans insured under the new FHA Title I program. The issuance of these pooling guidelines completes the implementation of the FHA Title I program passed as part of the Housing and Economic Recovery Act (HERA) in 2008. The issuance of these guidelines will now also provide FHA Title I lenders and Ginnie Mae approved Issuers the ability to securitize manufactured FHA Title I loans.

Effective with issuances on or after October 1, 2010, issuers may pool manufactured home loans insured under the FHA Title I program electronically through GinnieNET.

A few key highlights include:

• The securities rate must be at least 3.25 percent lower than the lowest face rate on the loans, but not more than 4.75 percent lower than the highest face rate of the security.
• The guarantee fee for MH MBS remains at 30 bps, and each pool must contain at least eight loans. The minimum pool balance, at origination, will increase to $1 million.
• The program is retroactive for any FHA loans originated since June 1, 2009.

A link to the two-page Ginnie Mae memorandum is here.

A link to the full requirements can be found here.

These pooling requirements appear consistent with lender expectations according to discussion MHI has had.

However, MHI has held several meetings with Ginnie Mae and FHA senior staff regarding our request for changes to the eligibility standards, in other words, what requirements do lenders have to meet just to participate in the Ginnie Mae program. While MHI supports strongly the premise that the program must be protected from future losses and that lenders must have adequate new worth requirements, MHI believes that some considerations can be made to responsibly ease the burden of lenders to participate as a Ginnie Mae Issuer. Please note that a lender can be an FHA lender and originate loans insured by FHA, and yet not be a Ginnie Mae approved Issuer. According to Ginnie Mae, they have received multiple applications from lenders to be approved Issuers.

For more information, MHI members can contact Thayer Long at tlong@mfghome.org.