Mortgage Financing: Actuarial Soundness of the Federal Housing	 
Administration's Mutual Mortgage Insurance Fund (24-APR-02,	 
GAO-02-671T).							 
                                                                 
The Housing Affordability for America Act of 2002 establishes	 
risk-based capital requirements for the Mutual Mortgage Insurance
Fund of the Federal Housing Administration (FHA). Through the	 
fund, FHA operates a single-family insurance program that helps  
millions of Americans buy homes. The Fund's estimated value rose 
dramatically in 1999, prompting proposals to spend current	 
resources or reduce net cash flows into the Fund. The value of	 
the Fund at the end of fiscal year 1999 was $15.8 billion. This  
capital ratio of 3.20 percent of the unamortized		 
insurance-in-force exceeded the minimum required capital ratio of
two percent. A two-percent capital ratio appears sufficient to	 
withstand moderately severe economic downturns that could lead to
worse-than-expected loan performance. Determining an appropriate 
capital ratio depends on the level of risk Congress wishes the	 
Fund to withstand. FHA faces the failure of borrowers to perform,
or credit risk, and the risk of managerial shortcomings, or	 
operational risk. By defining the risk that the Fund must	 
withstand, the act will define actuarial soundness and help FHA  
manage the Fund.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-671T					        
    ACCNO:   A03174						        
  TITLE:     Mortgage Financing: Actuarial Soundness of the Federal   
Housing Administration's Mutual Mortgage Insurance Fund 	 
     DATE:   04/24/2002 
  SUBJECT:   Economic analysis					 
	     Funds management					 
	     Mortgage loans					 
	     Mortgage programs					 
	     Mortgage protection insurance			 
	     Risk management					 
	     Mutual Mortgage Insurance Fund			 

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GAO-02-671T
     
Testimony Before the Subcommittee on Housing and Community Opportunity,
Committee on Financial Services, House of Representatives

United States General Accounting Office

GAO For Release on Delivery Expected at 2: 00 p. m. EDT Wednesday April 24,
2002

MORTGAGE FINANCING Actuarial Soundness of the Federal Housing
Administration?s Mutual Mortgage Insurance Fund

Statement of Thomas J. McCool, Managing Director Financial Markets and
Community Investment

GAO- 02- 671T

Page 1 GAO- 02- 671T

Madam Chairman and Members of the Subcommittee: We are here today to discuss
H. R. 3995, the Housing Affordability for America Act of 2002, which amends
certain laws concerning housing and community opportunity. Among other
things, the act would establish riskbased capital requirements for the
Mutual Mortgage Insurance Fund (Fund) of the Department of Housing and Urban
Development?s (HUD) Federal Housing Administration (FHA). Through the Fund,
FHA operates a single- family insurance program that helps millions of
Americans buy homes. The Fund, which is financed through insurance premiums,
operates without cost to the American taxpayer. The Fund?s estimated
economic value increased dramatically in 1999, prompting proposals to spend
some of the Fund?s current resources or reduce net cash flows into the Fund.
Concerned about the adequacy of the minimum 2- percent requirement set in
current law and about proposals to spend what some were calling excess
reserves, you asked us to determine the conditions under which an estimated
capital ratio of 2 percent would be adequate to maintain the Fund?s
financial health. We first presented the results of this analysis last year
and suggested ways to better evaluate the financial health of the Fund. 1 My
testimony today is based on that work and focuses on Section 226 of H. R.
3995. I will (1) briefly describe what the Fund represents, (2) discuss the
results of our analysis of the adequacy of a 2- percent minimum requirement,
and (3) explain how the current measures of financial soundness could be
improved.

In summary:

 The economic value of the Fund consists of current capital resources-
primarily nonmarketable Treasury securities- plus estimates of the net
present value of future cash flows from the existing portfolio. Deriving
estimates of the value of future cash flows requires professional judgment
and, in practice, relies on complex economic models. Last year, we reported
that the Fund had an economic value of about $15.8 billion at the end of
fiscal year 1999. This estimate implies a capital ratio of 3.20 percent of
the unamortized insurance- in- force- a ratio that exceeds the minimum
required capital ratio of 2 percent that Congress set in 1990.

1 U. S. General Accounting Office, Mortgage Financing: FHA?s Fund Has Grown,
but Options for Drawing on the Fund Have Uncertain Outcomes, GAO- 01- 460
(Washington, D. C.: Feb. 28, 2001).

Page 2 GAO- 02- 671T

 Given the economic value of the Fund and the state of the economy at the
end of fiscal year 1999, we concluded in our report that a 2- percent
capital ratio appeared sufficient to withstand moderately severe economic
downturns that could lead to worse- than- expected loan performance. In
other words, under the economic scenarios that we developed to represent the
regional and national economic downturns the nation experienced between 1975
and 1999, the estimated capital ratio fell by only slightly less than 0.4
percentage points. Some more severe downturns that we analyzed also did not
cause the estimated capital ratio to decline by as much as 2 percentage
points. However, in the three most severe scenarios, an economic value of 2
percent of insurance- in- force would not have been adequate. Nonetheless,
because of the nature of such analysis, we urged caution in concluding that
the estimated value of the Fund today implies that the Fund would
necessarily withstand any particular economic scenario under all
circumstances.

 Determining an appropriate capital ratio depends in part on the level of
risk Congress wishes the Fund to withstand. While a 2- percent capital ratio
appears to permit the Fund to withstand worse- than- expected loan
performance that we estimated would occur under most of the scenarios we
tested last year, a 2- percent capital ratio would not be sufficient for the
Fund to withstand the most severe scenarios we tested. Whether the same is
true today depends on the level of the Fund today, any changes in how loans
perform, and the way the Fund is managed in the future. For these reasons,
we believe that maintaining a static 2- percent minimum capital ratio
requirement would not mean that the Fund would always be able to withstand
most of the scenarios we tested or any particular level of risk that the
Congress wishes the Fund to withstand. FHA faces two principal risks: the
failure of borrowers to perform, or credit risk, and the risk of managerial
shortcomings, or operational risk. Section 226 of H. R. 3995 seeks to use
risk- based concepts to better assess the financial health of the Fund. By
defining the risk that the Fund must withstand, H. R. 3995 will clarify what
is meant by actuarial soundness and help FHA manage the Fund to achieve that
goal.

Before I describe what the Fund represents, let me provide a brief history
of the Fund?s financial health.

Since 1990 the financial health of the Fund has been assessed by measuring
the Fund?s economic value- its capital resources plus the net present value
of future cash flows- and the related capital ratio (the economic value as a
percent of the Fund?s insurance- in- force). For most of its history, the
Fund has been relatively healthy; however, in fiscal year Background

Page 3 GAO- 02- 671T

1990 the Fund was estimated to have a negative economic value, and its
future was in doubt. To help place the Fund on a financially sound basis,
Congress enacted legislation in November 1990 that required the secretary of
HUD to, among other things, take steps to achieve a capital ratio of 2
percent by November 2000 and to maintain or exceed that ratio at all times
thereafter. The legislation also required the secretary to raise insurance
premiums and suspend the rebates, called distributive shares, that FHA
borrowers had been eligible to receive under certain circumstances.

The 1990 FHA reforms required that an independent contractor conduct an
annual actuarial review of the Fund. Using expected economic conditions,
these reviews have shown that during the 1990s, the estimated economic value
of the Fund grew substantially. As figure 1 shows, by the end of fiscal year
1995, the Fund had attained an estimated economic value that slightly
exceeded the amount required for a 2- percent capital ratio. Since that
time, the estimated economic value of the Fund has continued to grow and has
always exceeded the amount required for a 2- percent capital ratio. In the
most recent review, Deloitte & Touche (Deloitte) estimated the Fund?s
economic value at about $18.5 billion at the end of fiscal year 2001. This
sum represents about 3.75 percent of the Fund?s insurance- in- force- well
above the required minimum of 2 percent.

Page 4 GAO- 02- 671T

Figure 1: Comparison of Estimated Economic Value and 2 Percent of Insurance-
in- Force, 1989- 2000

Source: GAO analysis of Price Waterhouse (now PricewaterhouseCoopers) and
Deloitte & Touche data.

The economic value of the Fund consists of current capital resources and the
net present value of future cash flows. Current capital resources are
largely composes of nonmarketable Treasury securities. Cash flows into the
Fund from premiums and the sale of foreclosed properties; cash flows out of
the Fund to pay claims on foreclosed mortgages, premium refunds, and
administrative expenses. Estimating the net present value of future cash
flows is a complex exercise that requires extensive professional actuarial
judgment

At the end of fiscal year 1999, the Fund had capital resources of $14.3
billion. Using our models and forecasts of likely values of key economic
variables, we estimated that the Fund had a net present value of future cash
flows of $1.5 billion at that time. Thus we arrived at an estimated economic
value of $15.8 billion and a capital ratio of 3.20 percent. Given The Fund?s
Capital

Ratio Exceeds 3 Percent

Page 5 GAO- 02- 671T

the inherent uncertainty of these estimates and the professional judgments
involved, these numbers are comparable to those of Deloitte at the end of
1999, when Deloitte estimated that under expected economic conditions the
economic value was $16.6 billion and the capital ratio was 3.66 percent.
More recently, Deloitte estimated that under expected economic conditions,
the capital value was $18.5 billion at the end of fiscal year 2001 and the
capital ratio was 3.75 percent.

The Fund?s economic value principally reflects the large amount of capital
resources that the Fund has accrued. Because current capital resources are
the result of previous cash flows, the robust economy and higher premium
rates of most of the 1990s accounted for the accumulation of these
substantial capital resources. Good economic times that are accompanied by
relatively low interest rates and relatively high levels of employment are
usually associated with high levels of mortgage activity and relatively low
levels of foreclosure; therefore, cash inflows have been high relative to
outflows during this period.

The estimated value of future cash flows also contributed to the strength of
the Fund at the end of fiscal 1999. As a result of relatively low interest
rates and the robust economy, FHA insured a relatively large number of
mortgages in fiscal years 1998 and 1999, and these loans made up a large
portion of FHA?s insurance- in- force. Because of low interest rates, and
because forecasts of economic variables for the near future showed house
prices rising and unemployment and interest rates remaining fairly stable,
our models predicted that these new loans would have low levels of
foreclosure and prepayment. At the same time, we estimated that many FHA-
insured homebuyers would continue to pay FHA annual insurance premiums. 2
Thus, our models predicted that cash flowing into the Fund from mortgages
already in FHA?s portfolio at the end of fiscal year 1999 would be more than
sufficient to cover the cash outflows associated with these loans.

2 Most borrowers with FHA- insured loans who received them prior to
September 1983 were required to pay an annual insurance premium for the life
of the loan. In addition, most borrowers who received FHA- insured loans
after June 1991 and before January 2001 were required to pay an annual
insurance premium for up to the life of the loan, depending on loan type and
the initial loan- to- value ratio. Borrowers who received FHA- insured loans
between September 1983 and June 1991 were not required to pay annual
mortgage insurance premiums.

Page 6 GAO- 02- 671T

The future cash flows are estimates based on a number of assumptions about
the future, including predictions of mortgage foreclosures and the
likelihood that those holding FHA- insured mortgages will prepay their
loans. These predictions are based on statistical models that estimate past
relationships between foreclosures and prepayments and certain economic
variables, such as changes in house prices. To the extent that these
relationships are different in the future, the actual foreclosures and
prepayments will differ from the estimates.

Although our estimates and Deloitte?s estimates of the Fund?s capital ratio
under expected economic conditions are well above the required minimum of 2
percent, we cannot conclude on the basis of these estimates alone that the
Fund is actuarially sound. Instead, we believe that determining actuarial
soundness requires, at a minimum, measuring the Fund?s ability to withstand
certain worse- than- expected conditions. According to our estimates, worse-
than- expected loan performance that could be brought on by moderately
severe economic conditions would not have caused the estimated value of the
fund at the end of fiscal year 1999 to decline by more than 2 percent of
insurance- in- force. Some more severe scenarios that we analyzed also did
not cause the estimated capital ratio to decline by as much as 2 percentage
points. However, the most severe economic scenarios could result in such
poor loan performance that the estimated value of the fund at the end of
fiscal year 1999 could decline by more than 2 percent of insurance- in-
force.

To help determine the Fund?s ability to withstand certain worse-
thanexpected conditions, we generated economic scenarios that were based on
economic events in the last 25 years and other scenarios that could lead to
worse- than- expected loan performance in the future. Under each of these
scenarios, we used our models to estimate the economic value of the Fund and
the related capital ratio (table 1). Most of the individual scenarios we
looked at, by themselves, had only a small impact on the capital ratio. For
example, the worst historical scenario we tested- one based on the 1981- 82
national recession- lowered the capital ratio by less than 0.4 percentage
points- about 20 percent of the required 2- percent minimum capital ratio.
To see how the economic value of the Fund would change as the extent of
adversity increased, we extended regional scenarios that were based on
historical economic downturns experienced in three states- the west south
central downturn, based on Louisiana in The Actuarial

Soundness of the Fund Depends on the Risks That Congress Wants the Fund to
Withstand

Page 7 GAO- 02- 671T

the late 1980s; the New England downturn, based on Massachusetts in the late
1980s and early 1990s; and the Pacific downturn, based on California in the
1990s- to the nation as a whole. 3 When we extended the west south central
and Pacific downturns, the estimated capital ratio was about 1 percentage
point lower than in the base case. However, our models estimate that
extending the New England downturn to the country as a whole would reduce
the capital ratio by almost 2.4 percentage points. In another scenario, we
specify that interest rates fall substantially, inducing refinancing, and
then a recession sets in, leading to increased foreclosures. The estimated
capital ratio in this case fell substantially- by over 1.8 percentage
points.

In one other scenario, the capital ratio fell by over 2 percentage points.
In that scenario we assumed that for mortgages originated in 1989 through
1999, the foreclosure rates in 2000 through 2004 would equal the foreclosure
rates from 1986 through 1990 for mortgages originated in the 10- year period
prior to 1986.

Table 1: Capital Ratios Under Expected and More Severe Economic Scenarios in
Selected Locations Scenario Description

Capital ratio for scenarios in one

region (percent)

Capital ratio for national scenarios

(percent)

Expected economic conditions Unemployment and interest rates vary as DRI
forecasts; house price growth is adjusted for constant quality and slower
growth. a

NA 3.20

Historical regional downturns

West south central downturn House prices and unemployment rates change as
they did in Louisiana from 1986 through 1990.

3.06 2.31 New England downturn House prices and unemployment

rates change as they did in Massachusetts from 1988 through 1992.

3.14 0.81 Pacific downturn House prices and unemployment

rates change as they did in California from 1991 through 1995.

2.89 2.16

3 The west south central region is comprised of Arkansas, Louisiana,
Oklahoma, and Texas. The Pacific region is comprised of Alaska, California,
Hawaii, Oregon, and Washington. The New England region is comprised of
Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont.

Page 8 GAO- 02- 671T

Scenario Description Capital ratio for

scenarios in one region (percent)

Capital ratio for national scenarios

(percent) Other national scenarios

1981- 82 Recession For each state, house prices, unemployment rates, and
interest rates change as they did from 1981 through 1985.

NA 2.81 Induced refinancing, followed by a recession Mortgage interest rates
fall,

inducing borrowers to refinance, and then a recession sets in, with a rising
unemployment rate and falling house prices.

NA 1.37 Rising interest rate scenario Mortgage and other interest rates

from 2000 through 2004 are higher than under expected economic conditions.

NA 3.36 Scenario with foreclosure rates from the 1980s Foreclosure rates in
2000 through

2004 equal foreclosure rates from 1986 to 1990 for mortgages originated in
most recent 10- year period.

NA 0.92 a Standard and Poor?s DRI is a private economic forecasting company.
Source: GAO analysis.

Because none of our economic scenarios generated foreclosure rates as high
as those experienced in the west south central states in the late 1980s, we
applied these rates directly to our models, assuming that for the next 5
years foreclosure rates in most cases would be equivalent to those
experienced by these states in 1986 through 1990. Then we varied the
proportion of FHA?s portfolio experiencing these foreclosure rates. As
figure 2 shows, if about 36 percent of the portfolio experiences these
rates, the estimated capital ratio would be 2 percentage points lower than
the expected case. And if 55 percent of the portfolio experienced these
rates, the economic value of the Fund would fall to zero.

Page 9 GAO- 02- 671T

Figure 2: Capital Ratios Resulting from Applying the Average 1986- 90
Foreclosure Rates in the West South Central Census Division to Varying
Proportions of FHA?s Insurance Portfolio in 2000- 2004

Note: West south central mortgages made up 9 percent of FHA?s portfolio in
1999. This analysis does not change foreclosure rates for streamline
refinanced or adjustable rate mortgages, as little information is available
on these products for the 10- year period prior to 1986. The west south
central Census division includes Arkansas, Louisiana, Oklahoma, and Texas.

Source: GAO analysis.

As we have stated in the past, considerable uncertainty is associated with
any estimate of the economic value of the Fund because of uncertainty about
the performance of FHA?s loan portfolio over the life of the existing loans,
which in some cases can be 30 years. We believe that our models make good
use of historical experience in identifying the key factors that influence
loan foreclosures and prepayments and estimating the relationships between
those factors and loan performance. In addition, we have relied on
reasonable and in some cases conservative forecasts of economic variables,
such as the rate of house price appreciation and the unemployment rate, in
finding that the Fund?s economic value in fiscal year 1999 appeared higher
than what would have been necessary to withstand many adverse economic
scenarios.

Page 10 GAO- 02- 671T

Nonetheless, several additional factors lead us to believe that Congress and
others should apply caution in concluding that the estimated value of the
Fund today implies that the Fund could withstand the economic scenarios that
we examined under all circumstances. Our estimates and those of others are
valid only under a certain set of conditions, including that loans FHA
insured in recent years and loans it insured in the more distant past have a
similar response to economic conditions, and that cash inflows associated
with future loans at least offset cash outflows associated with those loans.
Some specific factors beyond those incorporated in our models that could
determine the extent to which the Fund will be able to withstand adverse
economic conditions include the performance of recent loans, changes in
FHA?s insurance program, and the impact of future loans.

As a result of the 1990 housing reforms, the Fund must meet not only the
minimum capital ratio requirement but also operational goals, before the
secretary of HUD can take certain actions that might reduce the value of the
Fund. These goals include meeting the mortgage credit needs of certain
homebuyers while maintaining an adequate capital ratio, minimizing risk, and
avoiding adverse selection. However, the legislation does not specify the
economic conditions that the Fund should withstand. We believe that
actuarial soundness depends on a variety of factors that could vary over
time and that the degree of risk the Fund is expected to be able to
withstand must be specified. Therefore, setting a minimum or target capital
ratio will not guarantee that the Fund will be actuarially sound over time.
For example, if the Fund comprised primarily seasoned loans with known
characteristics, a capital ratio below the current 2percent minimum might be
adequate. But under conditions such as those that prevail today, when the
Fund is composed of many new loans, a 2- percent ratio might be inadequate
if recent and future loans perform considerably worse than expected.

Price Waterhouse (now PricewaterhouseCoopers) concluded in 1989 that for the
Fund to be actuarially sound, it should have capital resources that could
withstand losses from reasonably adverse, but not catastrophic, economic
downturns. The Price Waterhouse report did not clearly distinguish adverse
from catastrophic downturns; however, it said that private mortgage insurers
are required to hold contingency reserves to protect against catastrophic
losses. One rating agency requires that private mortgage insurers have
enough capital on hand to withstand the severe losses that would occur if
the loans they insure across the entire nation performed as poorly as those
in the west south central states in the 1980s. Measures of Actuarial

Soundness Should Be Based on a Defined Level of Risk

Page 11 GAO- 02- 671T

There are reasons why the capital standards for FHA might differ from those
imposed on private mortgage insurers. FHA is expected to meet a public
purpose, increasing the number of Americans who can afford to own their own
homes and helping to cushion the impact of economic downturns on housing
markets and the building trades. In contrast, private insurers tend to cease
insuring new business when mortgage markets go bad. Ultimately, if the Fund
were to exhaust its resources, it could rely on the taxpayer, while private
insurers would cease to exist.

We believe that to evaluate the actuarial soundness of the Mutual Mortgage
Insurance Fund, one or more scenarios that the Fund is expected to withstand
need to be specified, as a single, static capital ratio does not measure
actuarial soundness. Once the scenarios are specified, it would be
appropriate to calculate the economic value of the Fund or the capital ratio
under the scenarios. As long as the scenarios result in a positive estimated
economic value, the Fund could be said to be actuarially sound. However, it
might be appropriate to leave a cushion to account for the factors not
captured by the model, especially those related to managing the Fund and the
inherent uncertainty attached to any forecast.

Our view is that Section 226 of H. R. 3995 will permit FHA to develop
capital standards that more adequately reflect the risks the Fund faces. It
recognizes that FHA faces two principal risks: credit risk and operational
risk. By establishing what it calls a ?minimum risk- based capital ratio?
that is based upon economic scenarios that could adversely affect defaults
and prepayments, the act would more fully capture the credit risk the Fund
faces. By establishing a 1 percent ?minimum basic capital ratio,? the act
recognizes the unknown risk, such as operational risk, the Fund faces.
Overall, Section 226 of H. R. 3995 seeks to provide a method for determining
whether the Fund has capital adequate to cover its credit risk under defined
conditions and provides a cushion to cover continuing operational risk. By
defining the level of risk that the Fund must withstand, Section 226 will
clarify what is meant by actuarial soundness and help FHA manage the Fund to
achieve that goal.

Madam Chairman, this concludes my statement. We would be pleased to respond
to any questions that you or Members of the Subcommittee may have.

Page 12 GAO- 02- 671T

For further information regarding this testimony, please contact Thomas J.
McCool at (202) 512- 8678. Individuals making key contributions to this
testimony included Nancy Barry, Jay Cherlow, and Mathew Scire. Our work was
conducted in accordance with generally accepted government auditing
standards.

Mortgage Financing: Actuarial Soundness of the Federal Housing
Administration?s Mutual Mortgage Insurance Fund (GAO- 01- 527T, Mar. 20,
2001).

Mortgage Financing: FHA?s Fund Has Grown, but Options for Drawing on the
Fund Have Uncertain Outcomes (GAO- 01- 460, Feb. 28, 2001).

Mortgage Financing: Financial Health of the Federal Housing Administration?s
Mutual Mortgage Insurance Fund (GAO/ T- RCED- 00- 287, Sept. 12, 2000).

Mortgage Financing: Level of Annual Premiums That Place a Ceiling on
Distributions to FHA Policyholders (GAO/ RCED- 00- 280R, Sept. 8, 2000).

Single- Family Housing: Stronger Measures Needed to Encourage Better
Performance by Management and Marketing Contractors (GAO/ T- RCED00- 180,
May 16, 2000, and GAO/ RCED- 00- 117, May 12, 2000).

Single- Family Housing: Stronger Oversight of FHA Lenders Could Reduce HUD?s
Insurance Risk (GAO/ RCED- 00- 112, Apr. 28, 2000).

Homeownership: Information on Single- Family Loans Sold by HUD (GAO/ RCED-
99- 145, June 15, 1999).

Risk- Based Capital: Regulatory and Industry Approaches to Capital and Risk
(GAO/ GGD- 98- 153, July 20, 1998).

Homeownership: Achievements of and Challenges Faced by FHA?s SingleFamily
Mortgage Insurance Program (GAO/ T- RCED- 98- 217, June 2, 1998).

Homeownership: Results of and Challenges Faced by FHA?s Single- Family
Mortgage Insurance Program (GAO/ T- RCED- 99- 133, Mar. 25, 1999).

Homeownership: Management Challenges Facing FHA?s Single- Family Housing
Operations (GAO/ T- RCED- 98- 121, Apr. 1, 1998). Contact and

Acknowledgments Related GAO Products

Page 13 GAO- 02- 671T

Homeownership: Information on Foreclosed FHA- Insured Loans and HUD- Owned
Properties in Six Cities (GAO/ RCED- 98- 2, Oct. 8, 1997).

Homeownership: Potential Effects of Reducing FHA?s Insurance Coverage for
Home Mortgages (GAO/ RCED- 97- 93, May 1, 1997).

Homeownership: FHA?s Role in Helping People Obtain Home Mortgages (GAO/
RCED- 96- 123, Aug. 13, 1996).

Mortgage Financing: FHA Has Achieved Its Home Mortgage Capital Reserve
Target (GAO/ RCED- 96- 50, Apr. 12, 1996).

Homeownership: Mixed Results and High Costs Raise Concerns about HUD?s
Mortgage Assignment Program (GAO/ RCED- 96- 2, Oct. 18, 1995).

Mortgage Financing: Financial Health of FHA?s Home Mortgage Insurance
Program Has Improved (GAO/ RCED- 95- 20, Oct. 18, 1994).

(250086)
*** End of document. ***