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Objectives, Scope, and Methodology Appendix I

To examine trends in the use of down payment assistance with loans insured by the Federal Housing Administration (FHA), we obtained loan data from the U.S. Department of Housing and Urban Development (HUD) on single-family purchase money mortgage loans—that is, loans used for the purchase of a home rather than to refinance an existing mortgage.

First, to measure the use of down payment assistance from fiscal year 2000 to 2002, we used two samples of loans originally drawn for a file review study funded by HUD and conducted by the Concentrance Consulting Group (Concentrance).1 That study found that FHA’s Single-Family Data Warehouse was not a reliable source for identifying loans with down payment assistance. A review of paper files indicated that down payment assistance was frequently not recorded in the database and that the source of the assistance (government, nonprofit, relative, etc.) was often

miscoded. Therefore, we limited our review to the 8,294 files reviewed by Concentrance for which the presence, source, and amount of assistance had been ascertained from a review of the paper files. The national sample consisted of just over 5,000 loans from a simple random sample of FHA purchase money loans endorsed in fiscal years 2000, 2001, and 2002, while the Metropolitan Statistical Area (MSA) sample consisted of just over 1,000 purchase money loans from each of the three MSAs (Atlanta, Indianapolis, and Salt Lake City) endorsed over the same time period.2 Only loans with loan-to-value (LTV) ratios greater than 95 percent were sampled. The sample included loans insured by FHA’s 203(b) program, its main single-family program, and its 234(c) condominium program. Small specialized programs, such as 203(k) rehabilitation and 221(d) subsidized mortgages were not included in the sample.

Second, to measure the use of down payment assistance for fiscal years 2003, 2004, and 2005, we obtained from HUD loan-level data for single-family purchase money loans with an LTV ratio greater than 95 percent. We utilized HUD’s loan-level data for these years, because in January 2003 FHA implemented changes to its data collection requirements for loans with

1For a full description of this sample, see Concentrance Consulting Group, Audit of Loans with Downpayment Assistance, prepared for the U.S. Department of Housing and Urban Development, Feb. 6, 2004.

2According to HUD officials, HUD selected the Atlanta and Indianapolis MSAs for the Concentrance review because the use of down payment assistance was relatively high in those MSAs. HUD chose the Salt Lake City MSA because it had relatively high rates of down payment assistance and relatively high claim rates.

Appendix I

Objectives, Scope, and Methodology

down payment assistance. We believed that these changes should lead to improved data quality.

We analyzed the data, by source of assistance, for trends in loan volume and in the proportion of loans with down payment assistance. For fiscal years 2000, 2001, and 2002, we generalized the percentage breakouts from the representative sample to the universe of FHA-insured single-family purchase money loans endorsed in these years. We also analyzed state-by-state variations in the proportion of loans with nonprofit down payment assistance; loans endorsed from May 2004 through April 2005 were

included in this analysis. We met with appropriate FHA officials to discuss the quality of the data. Based on these discussions, we determined that the FHA data we used were sufficiently reliable for our analysis.

To examine the structure of the purchase transaction for loans with and without down payment assistance, we reviewed HUD policy guidebooks and reports on down payment assistance. We also interviewed HUD officials; staff from Fannie Mae and Freddie Mac; staff from selected conventional mortgage providers, private mortgage insurers, mortgage industry groups representing realtors and appraisers, state and local government agencies, and nonprofit down payment assistance providers;

and individual real estate agents and appraisers. During the interviews, we asked a structured set of questions designed for the particular type of industry participant. We also reviewed the Web sites of selected mortgage industry participants.

To examine how down payment assistance impacts the prices of houses purchased with FHA-insured loans, we examined the sales prices of homes by the use and source of down payment assistance using property value estimates derived from an Automated Valuation Model (AVM).3 We contracted with First American Real Estate Solutions to obtain property value estimates derived from their AVMs on two samples of FHA-insured single-family purchase money loans. One sample included the data set of 8,294 loans endorsed in fiscal years 2000, 2001, and 2002—the sample developed by Concentrance. The second sample included a stratified random sample of 2,000 FHA purchase money loans with first amortization

3AVM is a broad term used to describe a range of computerized econometric models that are designed to provide estimates of residential real estate property values. AVMs may use regression, adaptive estimation, neural networking, expert reasoning, and artificial intelligence to estimate the market value of a residence.

Appendix I

Objectives, Scope, and Methodology

dates in April 2005, extracted from FHA's Single-Family Data Warehouse.4 We used the AVM data as benchmarks to determine if a relationship existed between property valuation and the presence and source of down payment assistance by examining the ratio of the estimated AVM value to the appraised value and the sales price of the home. We met with staff of First American Real Estate Solutions to discuss the data and models in their AVM, including the steps the firm takes to verify the accuracy and maintain the integrity of the data. Based on these discussions, we determined that the AVM data we used were sufficiently reliable for our analysis. For a detailed description of our data sources and analysis, see appendix II.

To evaluate the influence of down payment assistance on the performance of FHA-insured home mortgage loans, we conducted multiple loan

performance analyses on HUD data for the sample of loans endorsed in fiscal years 2000, 2001, and 2002. We used information on the source of down payment funds—data developed by Concentrance; delinquency, claim, and loss data; and other factors that research had indicated can affect loan performance. The loan performance data we used were current through June 30, 2005. First, we analyzed loan performance by source of down payment assistance, controlling for the maximum age of the loan.

Second, we compared the performance of the loans by the presence and source of down payment assistance while holding other variables constant.

Third, we examined the size of the effect of down payment assistance on loan performance relative to the size of the effect of other variables that influence loan performance, including LTV ratio and credit score. Fourth, using AVM data obtained from First American Real Estate Solutions for these loans, we also assessed the extent to which higher sales prices explained any difference in the performance of FHA-insured loans with down payment assistance. For a detailed description of our data sources, performance measures, and risk models, see appendix III.

To examine the extent to which FHA standards and controls for loans with down payment assistance are consistent with government internal control guidelines and, as appropriate, mortgage industry practices, we first assessed whether key FHA controls were consistent with the guidelines in GAO’s August 2001 Internal Control Management and Evaluation Tool.5

4The date of first amortization is generally the first day of the month after settlement, so that most of these loans would have been settled during March 2005.

5GAO-01-1008G.

Appendix I

Objectives, Scope, and Methodology

These guidelines include (1) ensuring that an agency’s operations are consistent with any applicable industry or business norms; (2) using qualitative and quantitative methods to identify risk and determine relative risk rankings on a scheduled and periodic basis; (3) ensuring that adequate mechanisms exist to identify risks to the agency arising from its reliance on external parties to perform critical agency operations; and (4) ensuring that statutory requirements—as well as agency requirements, policies, and regulations—are applied properly. Second, we compared FHA’s standards and controls to mortgage industry practices, as appropriate. We

interviewed officials from HUD, Fannie Mae, Freddie Mac, conventional mortgage providers, private mortgage insurers, state and local government agencies, and nonprofit down payment assistance providers. These entities provided us with information about the controls they reported using to manage the risks associated with affordable loan products that permit down payment assistance. We did not verify that these entities, in fact, used these controls. We also reviewed descriptions of mortgage products permitting down payment assistance that are supported by mortgage industry participants and compared the standards used by these entities.

Appendix II