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Making Home Affordable Program Performance Report Third Quarter 2017 PROGRAM PERFORMANCE REPORT THROUGH THE THIRD QUARTER OF 2017 Making Home Affordable Program Performance Report Third Quarter 2017 • • • The MHA Program closed to new applicants on December 31, 2016. As set forth in program guidelines, MHA servicers were required to evaluate applications submitted by the deadline and offer modifications to eligible applicants. Servicers were required to design policies and procedures to reasonably ensure that all MHA transactions were completed by December 1, 2017. Although the MHA Program is now closed, servicers will continue to perform certain functions. This includes, for example, receiving and disbursing financial incentive payments, processing interest rate step-ups, and reporting MHA data to Treasury’s system of record. Treasury will continue to monitor these remaining activities, and publish relevant data about MHA on www.financialstability.gov. The content and format of such data is being revised to reflect the wind-down of MHA. See Appendix (page 10) for more details. More than 2.9 million homeowner assistance actions1 have taken place under MHA programs. HAMP Activity All Trials Started Trial Modifications 2,536,766 Tier 1 Tier 2 Median monthly housing payment savings on HAMP Mods3 Streamline HAMP All Permanent Modifications Started 1,732,490 Tier 1 1,472,347 Tier 2 216,889 Streamline HAMP Active Permanent Modifications 43,254 908,972 Other MHA Program Activity $3.7 billion Cumulative homeowner debt relief through HAFA (non-GSE loans) 3,107 $24.5 billion Cumulative principal balance extinguished under 2MP 60,108 $53.2 billion Cumulative principal balance reduced on HAMP mods 237,295 $466.08 Estimated cumulative payment savings on HAMP mods 2,239,363 Active Trials Permanent Modifications Program Results $30.3 billion For more information about Treasury’s housing programs, please visit: http://www.treasury.gov/initiatives/financial-stability/TARP-Programs/housing/Pages/default.aspx. 1 Program-to-Date FHA and RD-HAMP Permanent Modifications Started 141,510 2MP Modifications Started 166,057 HAFA Transactions Completed1 472,904 UP Forbearance Plans Started2 46,485 Program Total Includes: Government Sponsored Enterprise (GSE) and Non-GSE HAMP permanent modifications; Treasury FHA- and RD-HAMP modifications; and GSE Standard Modifications since October 2011 under the GSEs’ Servicer Alignment Initiative as reported by the GSEs to Treasury. HAFA Transactions Completed in the ‘Other MHA Program Activity’ table includes both GSE and Non-GSE HAFA transactions completed, including those completed by the GSEs since the GSEs jointly streamlined their short sale and deed-in-lieu of foreclosure programs in November 2012. The GSE Standard HAFA program is closely aligned with Treasury’s MHA HAFA program. For details on all GSE programs, visit http://www.FHFA.gov/. 2 The Unemployment Program total reflects activity through the program end date of 12/30/2016 as reported by servicers in the final monthly program survey. 3 Excludes the impact of any interest rate increases. 2 Making Home Affordable Program Performance Report Third Quarter 2017 HAMP Tier 1 Interest Rate Increases • Approximately 80% of HAMP Tier 1 homeowners will experience an interest rate increase after five years. o The median amount of the first monthly payment increase is $93, and the median monthly payment increase after the final interest rate increase is $207. • Through September 2017, more than 530,000 homeowners have experienced one interest rate step-up, approximately 394,000 have experienced a second rate step-up, and about 209,000 have experienced a third rate step-up. o Based on reported data, the rate increase does not appear to have an impact on the performance of these modifications. The percentage of modifications disqualifying in the month following the reset remains consistent with the months leading up to the reset, at less than or equal to 1%. • To help mitigate the impact of interest rate step-ups, servicers can offer borrowers the opportunity to recast their HAMP modifications upon reaching their sixth-year anniversary. To date, approximately 61,900 loans have been recast, 90% of which experienced an interest rate step-up. Monthly payments for recast loans have been reduced by a median of $56. Number of Interest Rate Increases by Year1 500,000 450,000 Number of Loans 400,000 350,000 300,000 250,000 200,000 150,000 100,000 50,000 0 2014 2015 2016 First Increase 1 As of September 2017. Assumes no future re-defaults of HAMP Tier 1 modifications. 2017 2018 Second Increase 2019 2020 Third Increase 2021 2022 2023 2024 Fourth Increase 3 Making Home Affordable Program Performance Report Third Quarter 2017 Performance of HAMP Permanent Modifications The tables below show the performance of HAMP permanent modifications at various seasoning points for those modifications that have aged to, or past, the number of months noted. Note that far fewer loans have reached these seasoning points for HAMP Tier 2, which was introduced in 2012. % of Disqualified Modifications:1 2009 2010 2011 2012 2013 2014 2015 2016 Q1 2017 Q2 2017 Q3 2017 All 2.1% 1.7% 1.2% 1.0% 0.8% 1.2% 1.3% 1.3% 1.2% 1.4% 1.3% 1.3% 6 6.7% 6.8% 5.3% 4.3% 3.8% 4.7% 5.3% 5.6% 4.6% 6.2% 12 16.3% 15.6% 12.7% 10.3% 9.5% 10.6% 11.8% 12.8% 13.1% 18 22.9% 22.7% 18.9% 15.3% 14.0% 15.3% 17.0% 18.2% 19.2% 24 28.8% 28.1% 23.8% 19.1% 17.3% 18.8% 20.8% 23.9% 30 33.3% 32.7% 27.3% 22.1% 19.9% 21.7% 23.4% 27.7% 36 37.6% 36.6% 30.1% 24.6% 22.1% 24.3% 31.1% 42 41.1% 39.4% 32.5% 26.7% 24.2% 26.1% 33.8% 48 43.6% 41.7% 34.7% 28.6% 26.4% 36.4% 54 46.0% 43.6% 36.5% 30.5% 28.7% 38.9% 60 HAMP Tier 1 # Months Post Modification 3 47.9% 45.6% 38.5% 32.9% 5.5% 41.7% 1.3% 1.9% 1.7% 1.8% 1.7% 1.4% 1.5% 6 5.4% 7.8% 7.1% 7.9% 7.5% 6.5% 7.6% 12 17.4% 17.3% 16.2% 17.6% 17.5% 17.2% 18 23.2% 24.5% 22.6% 24.7% 24.5% 24.0% 24 28.7% 29.0% 27.6% 30.0% 28.9% 30 32.1% 32.4% 31.6% 34.0% 32.3% 36 34.6% 34.9% 34.8% 34.9% 42 37.7% 38.0% 38.3% 38.1% 48 HAMP Tier 2 3 39.8% 41.2% Servicers did not submit 11.0% of the total required OMRs for loans aged up to 60 months in the current reporting period. Several factors, including Federally Declared Disaster designations, contributed to the larger than normal number of missing reports. In addition, reported loan counts may shift from prior reports due to servicer data corrections. For example, if it was assumed that all unreported OMRs reflect either a current payment status or the maximum number of missed payments based on the most recently submitted OMR, the re-default rate for Tier 1 permanent modifications that have aged 60 months may range between 41.3% and 41.4%. 2.3% 1.7% 7.5% 41.2% 1 4 Making Home Affordable Program Performance Report Third Quarter 2017 Incremental Performance of HAMP Modifications Over Time 3-Month Re-default Rate The longer homeowners remain in HAMP without defaulting, the less likely they are to default on their mortgage in the future. For example, the percent of loans active in month 12 that disqualified by month 15 is lower than the percent of loans active in month 6 that disqualified by month 9. These rates assume no future re-defaults. Conditional Re-default Rate for Tier 1 and Tier 2 Modifications by Modification Year (% of Active Loans) 7% 6% 5% 4% 3% 2% 1% 0% 6 9 12 15 18 2009 21 24 2010 27 30 33 36 39 42 Months After Conversion to Permanent Modification 2011 2012 2013 2014 2015 45 48 51 54 57 60 2016 Homeowners with Disqualified HAMP Permanent Modifications or Those Who Did Not Receive a HAMP Modification1 The majority of homeowners who disqualify from a HAMP permanent modification receive an alternative to foreclosure or resolve their delinquency. In addition, while not all homeowners qualified for HAMP, many have found alternative solutions to their delinquency. Homeowners with Disqualified HAMP Permanent Modifications Homeowners Who Did Not Receive a HAMP Modification 2% 1% 3% 6% Action Pending 20% 22% Action Not Allowed – Bankruptcy in Process 19% 5% Borrower Current/Loan Pay off Alternative Modification/ Payment Plan Short Sale / Deed-in-Lieu Foreclosure Starts 14% Foreclosure Completions 1% 37% 14% 21% 33% Survey data from large servicers. Data is for actions completed through the end of the reporting period and reflects the status of homeowners as of that date; a homeowner's status may change over time. Survey data is not subject to the same data quality checks as data uploaded into the HAMP system of record. Excludes cancellations and disqualifications pending data corrections and loans otherwise removed from servicing portfolios. 1 5 Making Home Affordable Appendix Program Performance Report Third Quarter 2017 Performance of HAMP Modifications by Vintage HAMP Tier 1 Delinquency: Months After Conversion to Permanent Modification 3 6 12 18 24 Mod. Effective in: # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days 2009Q3 3,565 10.7% 4.5% 4,386 15.8% 10.6% 4,585 25.8% 21.2% 4,919 32.2% 28.9% 5,020 36.8% 33.5% 2009Q4 43,336 5.7% 1.9% 47,133 10.2% 6.3% 50,984 20.4% 15.9% 54,155 25.5% 22.4% 55,101 31.6% 28.4% 2010Q1 123,494 4.3% 1.5% 149,705 10.4% 6.1% 160,499 20.4% 16.1% 165,508 26.0% 22.5% 167,329 31.9% 28.8% 2010Q2 147,040 5.3% 1.8% 156,650 12.3% 7.5% 172,951 19.6% 16.1% 170,181 27.8% 24.1% 178,313 31.1% 28.7% 2010Q3 85,925 5.1% 1.9% 95,584 11.1% 7.1% 103,859 18.3% 14.5% 105,822 25.3% 21.9% 105,867 29.5% 26.8% 2010Q4 57,823 4.6% 1.8% 62,275 8.9% 5.7% 64,901 18.4% 14.5% 66,432 24.0% 21.1% 66,200 29.6% 26.5% 2011Q1 70,572 2.9% 1.0% 75,538 8.3% 5.1% 79,250 17.1% 13.6% 80,835 22.3% 19.2% 80,506 27.6% 24.9% 2011Q2 79,592 3.7% 1.3% 88,847 9.4% 5.8% 92,353 16.2% 13.2% 91,652 23.1% 20.1% 91,259 27.3% 25.1% 2011Q3 80,623 3.7% 1.3% 85,680 8.8% 5.6% 86,668 15.5% 12.3% 86,431 21.8% 18.9% 84,910 25.8% 23.4% 2011Q4 64,722 3.4% 1.2% 67,235 6.9% 4.4% 67,588 14.7% 11.4% 67,751 19.3% 16.8% 67,466 23.4% 21.0% 2012Q1 49,171 2.5% 0.8% 50,605 6.7% 4.0% 50,638 14.1% 10.9% 50,031 18.5% 15.8% 50,536 22.5% 20.0% 2012Q2 43,824 3.0% 1.0% 44,802 7.7% 4.6% 45,075 13.6% 10.9% 44,572 18.9% 16.1% 44,775 22.1% 20.0% 2012Q3 47,129 3.1% 1.0% 48,819 7.4% 4.6% 49,543 13.0% 10.0% 50,042 17.9% 15.1% 50,293 20.9% 18.5% 2012Q4 39,176 3.2% 1.0% 41,095 6.3% 3.9% 42,307 12.3% 9.4% 42,554 16.3% 14.0% 42,682 19.9% 17.6% 2013Q1 39,142 2.2% 0.7% 40,796 6.0% 3.5% 41,918 12.6% 9.6% 42,285 16.6% 13.9% 42,068 19.9% 17.7% 2013Q2 31,444 2.6% 0.8% 32,921 6.5% 3.9% 33,629 11.8% 9.4% 33,915 16.6% 14.2% 34,055 19.2% 17.4% 2013Q3 31,827 2.9% 0.9% 33,300 7.0% 4.2% 34,699 12.2% 9.3% 34,508 16.5% 14.1% 34,660 18.9% 17.0% 2013Q4 27,217 3.0% 1.0% 28,536 6.3% 3.9% 29,818 12.3% 9.5% 29,835 16.2% 14.0% 29,825 19.3% 17.2% 2014Q1 23,618 2.5% 0.9% 25,516 6.9% 3.9% 26,365 13.2% 10.4% 26,299 16.7% 14.5% 26,388 19.9% 17.9% 2014Q2 18,979 3.7% 1.1% 19,785 7.8% 5.1% 20,405 13.1% 10.8% 20,365 18.0% 15.3% 20,469 20.4% 18.5% 2014Q3 16,947 3.6% 1.3% 17,788 8.1% 5.5% 18,360 13.5% 10.7% 18,412 18.5% 15.9% 18,362 21.6% 19.4% 2014Q4 15,077 3.9% 1.5% 16,842 7.2% 4.5% 17,276 14.1% 10.8% 17,482 18.2% 15.8% 17,266 22.1% 19.7% 2015Q1 14,769 2.9% 1.0% 15,743 7.3% 4.4% 16,155 14.1% 11.1% 16,154 18.6% 16.0% 16,170 22.8% 20.1% 2015Q2 14,234 4.0% 1.4% 14,781 9.1% 5.6% 15,074 15.1% 12.0% 15,067 20.0% 16.8% 15,120 22.9% 20.5% 2015Q3 12,611 3.9% 1.4% 13,051 8.9% 5.6% 13,320 15.3% 11.8% 13,268 21.0% 17.7% 13,279 23.9% 21.3% 2015Q4 10,446 4.2% 1.6% 10,908 8.6% 5.7% 11,152 15.9% 12.5% 11,118 20.8% 17.9% 3,654 26.0% 23.6% 2016Q1 9,614 3.3% 1.0% 10,002 8.4% 5.0% 10,195 16.2% 12.4% 10,163 20.6% 17.7% 2016Q2 8,736 4.2% 1.6% 9,205 9.3% 5.8% 9,431 16.2% 12.8% 2,994 22.7% 19.9% 2016Q3 7,969 4.4% 1.4% 8,398 9.6% 6.0% 8,586 16.6% 12.9% 2016Q4 6,606 4.5% 1.3% 7,013 8.6% 5.5% 2,269 18.4% 14.5% 2017Q1 5,779 3.5% 1.2% 6,031 7.8% 4.6% 2017Q2 4,383 4.6% 1.4% 1,659 10.7% 6.2% 2017Q3 635 4.1% 1.3% All 1,236,025 3.9% 1.3% 1,330,629 9.0% 5.5% 1,379,853 16.5% 13.1% 1,372,750 22.2% 19.2% 1,361,573 26.4% 23.9% 6 Making Home Affordable Appendix Program Performance Report Third Quarter 2017 Performance of HAMP Modifications by Vintage HAMP Tier 1 Delinquency: Months After Conversion to Permanent Modification 36 48 60 72 84 Mod. Effective in: # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days 2009Q3 5,121 43.8% 41.7% 5,029 49.9% 48.3% 5,009 53.9% 52.4% 4,758 59.3% 58.6% 4,432 66.5% 65.7% 2009Q4 55,913 39.7% 37.2% 55,655 44.9% 43.1% 54,903 48.9% 47.5% 52,708 53.8% 52.8% 49,196 60.3% 59.5% 2010Q1 165,630 39.7% 37.5% 165,339 44.6% 43.0% 162,791 48.5% 47.2% 156,855 53.2% 52.2% 146,058 59.7% 58.8% 2010Q2 174,600 39.3% 37.5% 173,736 43.8% 42.6% 172,498 47.2% 46.2% 165,221 52.1% 51.3% 154,101 58.4% 57.8% 2010Q3 104,158 37.2% 35.3% 104,709 41.3% 39.8% 102,425 45.0% 44.0% 98,068 49.8% 48.9% 92,309 55.3% 54.6% 2010Q4 65,688 36.3% 34.3% 65,680 40.4% 38.8% 64,603 43.8% 42.6% 62,163 48.0% 47.2% 18,867 56.3% 55.6% 2011Q1 80,633 33.9% 31.9% 80,097 38.0% 36.6% 78,322 41.4% 40.4% 74,059 46.6% 45.6% 2011Q2 91,263 33.2% 31.6% 90,757 37.2% 36.1% 88,364 40.8% 39.8% 83,669 45.8% 45.0% 2011Q3 86,608 31.0% 29.3% 84,749 35.4% 34.2% 81,838 39.2% 38.2% 78,109 43.6% 42.7% 2011Q4 67,547 28.5% 26.8% 66,469 32.3% 30.9% 64,668 35.7% 34.7% 21,176 42.3% 41.6% 2012Q1 50,079 28.0% 26.0% 49,482 31.3% 30.1% 47,942 35.0% 33.8% 2012Q2 44,696 27.0% 25.5% 43,674 30.7% 29.5% 42,164 34.2% 33.3% 2012Q3 49,581 25.6% 24.1% 48,342 29.3% 28.1% 46,592 32.8% 31.7% 2012Q4 42,067 24.2% 22.7% 40,924 28.0% 26.6% 12,026 33.7% 32.7% 2013Q1 41,560 24.1% 22.4% 40,317 27.9% 26.5% 2013Q2 33,906 23.4% 22.0% 32,962 27.4% 26.1% 2013Q3 34,239 23.5% 21.9% 33,200 27.4% 26.1% 2013Q4 29,479 23.6% 22.0% 9,087 29.1% 27.7% 2014Q1 26,065 25.2% 23.4% 2014Q2 20,315 25.5% 23.8% 2014Q3 18,108 26.9% 25.2% 2014Q4 5,074 29.3% 27.4% 1,292,330 32.9% 31.1% 1,190,208 37.8% 36.4% 1,024,145 42.8% 41.7% 796,786 49.6% 48.7% 464,963 58.4% 57.6% 2015Q1 2015Q2 2015Q3 2015Q4 2016Q1 2016Q2 2016Q3 2016Q4 2017Q1 2017Q2 2017Q3 All 7 Making Home Affordable Appendix Program Performance Report Third Quarter 2017 Performance of HAMP Modifications by Vintage HAMP Tier 2 Delinquency: Months After Conversion to Permanent Modification 3 6 12 18 24 Mod. Effective in: # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days # 60+ Days 90+ Days 2012Q3 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0% 1 100.0% 100.0% 1 100.0% 100.0% 2012Q4 946 5.3% 1.3% 1,116 9.9% 5.4% 1,187 23.6% 17.4% 1,244 28.1% 23.2% 1,257 33.4% 28.6% 2013Q1 2,476 4.3% 1.4% 2,710 12.5% 7.2% 2,871 24.9% 19.5% 2,975 31.1% 26.8% 3,009 35.9% 32.4% 2013Q2 4,100 5.4% 1.6% 4,450 13.9% 8.0% 5,053 22.0% 17.6% 5,156 29.3% 24.8% 5,194 32.5% 29.3% 2013Q3 11,198 6.0% 2.2% 13,195 14.0% 8.4% 13,620 22.4% 16.9% 13,526 29.2% 25.0% 13,831 32.3% 28.9% 2013Q4 11,200 5.9% 1.9% 11,784 11.9% 7.3% 12,597 22.3% 17.1% 12,500 26.9% 23.4% 12,642 31.6% 28.1% 2014Q1 10,494 4.1% 1.4% 11,601 12.2% 6.7% 12,009 21.7% 17.0% 11,793 26.8% 23.0% 12,009 30.9% 27.5% 2014Q2 10,872 5.5% 1.4% 11,182 13.0% 7.4% 11,290 20.0% 15.8% 11,200 26.7% 22.4% 10,993 31.0% 27.8% 2014Q3 9,158 5.8% 2.0% 9,463 12.8% 8.1% 9,936 20.3% 15.5% 9,826 26.7% 22.4% 9,824 30.4% 27.1% 2014Q4 11,041 5.8% 1.9% 12,679 11.3% 6.5% 12,897 21.6% 16.4% 13,251 26.8% 22.7% 13,145 31.6% 27.8% 2015Q1 13,063 4.6% 1.2% 14,040 12.1% 6.5% 14,211 22.3% 17.0% 14,135 27.7% 23.4% 14,194 33.4% 29.2% 2015Q2 13,937 6.0% 1.6% 14,243 14.2% 8.6% 14,310 23.1% 17.9% 14,355 29.9% 25.1% 14,443 33.5% 30.2% 2015Q3 14,262 6.8% 2.2% 14,691 14.8% 8.9% 14,936 22.7% 17.8% 14,815 30.1% 25.7% 14,863 33.8% 30.2% 2015Q4 11,818 6.6% 2.1% 12,070 12.6% 7.5% 12,519 22.6% 17.5% 12,539 28.4% 24.6% 4,091 34.5% 31.3% 2016Q1 12,581 4.7% 1.3% 13,087 12.0% 6.6% 13,298 23.0% 17.4% 13,292 28.5% 23.8% 2016Q2 12,794 5.5% 1.6% 13,246 14.1% 8.0% 13,570 22.6% 17.7% 4,276 31.3% 26.8% 2016Q3 12,455 6.3% 2.0% 12,969 14.2% 8.3% 13,185 22.7% 17.6% 2016Q4 10,153 6.2% 1.9% 10,770 11.7% 6.9% 3,562 22.5% 17.3% 2017Q1 8,971 4.4% 1.4% 9,236 11.5% 6.5% 2017Q2 7,098 5.2% 1.5% 2,681 13.1% 7.6% 2017Q3 984 5.7% 2.3% All 189,601 5.6% 1.7% 195,213 12.9% 7.5% 181,051 22.2% 17.2% 154,884 28.3% 24.0% 129,496 32.4% 28.9% 8 Making Home Affordable Appendix Program Performance Report Third Quarter 2017 Performance of HAMP Modifications by Vintage HAMP Tier 2 Delinquency: Months After Conversion to Permanent Modification Mod. Effective in: # 60+ Days 90+ Days # 60+ Days 90+ Days 2012Q3 1 100.0% 100.0% 1 100.0% 100.0% 2012Q4 1,283 39.0% 34.5% 1,250 42.0% 39.8% 2013Q1 3,232 38.9% 36.9% 3,133 43.9% 41.7% 2013Q2 5,257 37.3% 34.8% 5,112 42.4% 40.5% 2013Q3 14,012 37.3% 34.8% 13,569 42.8% 40.8% 2013Q4 12,708 37.2% 34.5% 4,353 45.1% 43.0% 2014Q1 11,876 37.3% 34.6% 2014Q2 11,182 36.9% 34.3% 2014Q3 9,641 37.7% 35.2% 2014Q4 3,592 39.0% 36.4% 72,784 37.5% 34.9% 27,418 43.2% 41.2% 36 48 2015Q1 2015Q2 2015Q3 2015Q4 2016Q1 2016Q2 2016Q3 2016Q4 2017Q1 2017Q2 2017Q3 All 9 Making Home Affordable Appendix Program Performance Report Third Quarter 2017 MHA Performance and Compliance Monitoring Treasury Monitors Performance of Participating Mortgage Servicers Treasury has monitored the performance of participating mortgage servicers since the MHA Program’s inception in 2009. Freddie Mac, acting as Treasury’s compliance agent, created a separate division known as Making Home Affordable–Compliance (MHA-C), which evaluates servicers’ compliance with MHA guidelines through regular compliance reviews. Over the years, these reviews have assessed servicers’ compliance with MHA guidelines in many areas, such as: • Identifying and contacting homeowners who are potentially eligible for MHA; • Evaluating homeowners’ eligibility for MHA programs and communicating decisions; • Remitting or applying financial incentives for the benefit of eligible homeowners; • Processing interest-rate step-ups, loan recasts and related notices to borrowers; • Processing MHA-modified loans that have lost good standing or are included in a transfer of servicing; and • Reporting MHA data to Treasury’s system of record. MHA-C reports the results of each compliance review to Treasury and the servicer. This approach provides Treasury with comprehensive insight into how each servicer is implementing MHA programs. Consequences of Non-Compliance Servicer participation in MHA is based on a contract with Fannie Mae, as financial agent on behalf of Treasury. It is important to note that Treasury does not regulate these institutions and does not have the authority to impose fines or penalties. Treasury can, pursuant to the contract, take certain remedial actions against servicers not in compliance with MHA guidelines. This includes requiring the servicer to correct identified instances of non-compliance, identify and re-evaluate affected loans, perform a retroactive analysis when an issue is potentially systemic, and enhance the effectiveness of the servicer’s internal controls. In addition, Treasury can implement financial remedies, such as withholding financial incentive payments owed to servicers until non-compliance is corrected. MHA Wind-Down The Consolidated Appropriations Act, 2016, signed into law on December 18, 2015, provided that the MHA Program would terminate on December 31, 2016, except with respect to certain loan modification applications made before such date. As set forth in program guidelines, MHA servicers were required to evaluate applications submitted before the deadline and offer trial modifications to eligible applicants. All MHA transactions must be completed by December 1, 2017. Following the completion of all MHA transactions on December 1, 2017, Treasury will continue to monitor servicer compliance with respect to those MHA guidelines that pertain to post-modification activities, and require remedial action as described above. 10
@FedFRASER