Homeownership: Information on Single-Family Loans Sold by HUD

Published by the Government Accountability Office on 1999-06-15.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  United States General Accounting Office

GAO               Report to the Subcommittee on Housing
                  and Transportation, Committee on
                  Banking, Housing and Urban Affairs,
                  U.S. Senate

June 1999

                  Information on Single-
                  Family Loans Sold by

United States General Accounting Office                                                           Resources, Community, and
Washington, D.C. 20548                                                                        Economic Development Division

                                    B-282006                                                                                        Letter

                                    June 15, 1999

                                    The Honorable Wayne Allard
                                    The Honorable John F. Kerry
                                    Ranking Minority Member
                                    Subcommittee on Housing and Transportation
                                    Committee on Banking, Housing, and Urban Affairs
                                    United States Senate

                                    In 1994, in an effort to make better use of its resources, the Department of
                                    Housing and Urban Development (HUD) undertook a program designed to
                                    liquidate its inventory of single-family loans. From June 1994 through
                                    September 1997, HUD sold 98,640 single-family loans in a series of six
                                    sales. Nearly all of these loans were acquired by HUD through its now
                                    defunct Mortgage Assignment Program, which, since 1976, had provided
                                    borrowers who had defaulted on their mortgages with reduced or
                                    suspended mortgage payments for a limited time.1 The purchasers of these
                                    loans agreed to offer borrowers the same forbearance, or lower loan
                                    payments, that HUD was required to offer before the loans were sold.
                                    According to HUD, these sales allowed the Department to achieve critically
                                    needed staff reductions and resulted in over $830 million in estimated
                                    budgetary savings.

                                    Concerned about the treatment of homeowners whose loans were sold,
                                    you asked us to describe (1) the current status of single-family loans sold
                                    and (2) the ways in which HUD has ensured that the purchasers of these
                                    loans abide by the forbearance requirements contained in the loan sales
                                    agreements. In addition, you asked us to provide information on the
                                    changes HUD has made in the staffing resources used to service the loans it

                                    1InJanuary 1996, the Congress passed legislation terminating the Single-Family Mortgage Assignment
                                    Program. As a result, HUD has not accepted any new applications for assignment since April 26, 1996.
                                    However, because of the large volume of last-minute filings, some applications for assignment were still
                                    being processed throughout 1997.

                                     Servicing a loan consists of, among other things, collecting mortgage payments, establishing and
                                    maintaining escrow accounts for the payment of real estate taxes, providing borrowers with annual
                                    financial reports, providing forbearance to borrowers, and initiating foreclosure procedures.

                                    Page 1                                             GAO/RCED-99-145 HUD’s Single-Family Loans

                   Only one of the loan servicers we contacted was willing to provide data on
                   the current status of single-family loans sold. However, this company
                   serviced 58,012 of the 98,640 single-family loans sold--29,348 loans it
                   purchased directly from HUD, and 28,664 loans owned by other purchasers
                   of HUD single-family loans.3

Results in Brief   As of the end of 1998, most homeowners whose loans were sold and for
                   which we had data on the current disposition of the loan, continued to own
                   their homes. According to the company responsible for servicing these
                   loans, for 55 percent of the 58,012 loans that it serviced, homeowners were
                   current under the original, or forbearance, agreement terms of the loans.
                   An additional 14 percent of the loans had been paid off or refinanced. The
                   remaining 31 percent of these loans were delinquent, pending foreclosure,
                   foreclosed, in bankruptcy, or resolved in some other way.

                   To ensure that the servicers of single-family loans honor the borrower
                   protections contained in the loan sales agreements--including reduced
                   mortgage payments--HUD conducted compliance reviews of loan servicers
                   and operated a toll-free telephone complaint and information line for
                   borrowers whose loans had been sold. Through these methods, HUD
                   found, among other things, that loan servicers sometimes did not
                   appropriately consider borrowers’ ability to pay higher payments and that
                   some borrowers thought loan servicers required too high a mortgage
                   payment. According to HUD, servicers have taken action to address the
                   findings and concerns raised by HUD’s compliance reviews and its
                   telephone complaint line. However, in some cases, HUD’s records either
                   do not show whether servicers took corrective action or do not describe
                   the corrective action taken.

                   While data on the staffing devoted specifically to servicing HUD-held loans
                   were not available, total staffing and staffing devoted to managing both
                   HUD-held loans and HUD-owned properties has declined dramatically,
                   particularly in the last 2 years. 4 Specifically, staff located in field offices
                   who were responsible for managing single-family loans and properties

                   3The purchasers of loans either serviced the loans themselves or hired other companies to do so. In
                   either case, the company that services the loan must be a HUD-approved loan servicer.

                    HUD acquires single-family properties when it forecloses on the loans it holds or when lenders
                   foreclose on HUD-insured loans. During fiscal year 1998, HUD had, on average, about 40,000 single-
                   family properties in its inventory.

                   Page 2                                            GAO/RCED-99-145 HUD’s Single-Family Loans

             declined by an estimated 56 percent--or 683 full-time equivalent staff--
             during fiscal years 1997 and 1998--over twice the rate of the total staffing
             decline during this period.5 This decline in staffing levels occurred despite
             an increasing workload resulting from property disposition. Furthermore,
             much of the decline in staffing occurred after HUD had dramatically
             reduced its inventory of HUD-held loans. According to HUD officials, the
             reduction in the inventory of HUD-held loans allowed the Office of Housing
             to decrease its staffing levels.

Background   In the early 1990s, HUD was being overwhelmed by a growing number of
             single-family loans entering its inventory of owned assets, mainly through
             its single-family Mortgage Assignment Program. As a result, there was
             increased demand on HUD’s resources to service these loans. In 1994, in an
             effort to make better use of its resources, HUD decided to sell its inventory
             of single-family loans. In June 1994, when HUD held its first loan sale, it
             owned over 100,000 single-family loans. Through a series of six sales, from
             June 1994 through September 1997, HUD sold 98,640 single-family loans.
             HUD’s single-family loans were sold without mortgage insurance--that is,
             HUD did not insure the purchasers of the loans against losses that would be
             caused by borrowers’ defaults. At the end of fiscal year 1998, HUD owned
             about 12,000 single-family loans.

             The majority of the loans sold by HUD were acquired through its now
             defunct Mortgage Assignment Program. This program allowed lenders,
             under certain conditions, to assign defaulted Federal Housing
             Administration (FHA)-insured mortgages to HUD, making HUD the owner
             of the loan. For borrowers accepted into the program, HUD paid the
             mortgage debt, took assignment of the loan from the lender, and developed
             a new repayment plan (forbearance agreement) for the borrower. Under
             this agreement, mortgage payments could be reduced or suspended for up
             to 36 months. HUD, acting as lender, collected monthly mortgage
             payments from the borrowers while allowing them to keep their home.

             By taking assignment of loans rather than having lenders foreclose on
             them, HUD can, at times, avoid foreclosure losses, help borrowers retain
             their homes, and provide these borrowers with an opportunity to avoid
             foreclosure. However, we reported in October 1995, that even with the

              A full-time equivalent is a measure of employment. It is determined by dividing the total number of an
             agency’s work hours within a fiscal year by 2,087, which is the number of hours in a federal workyear.

             Page 3                                             GAO/RCED-99-145 HUD’s Single-Family Loans

                              forbearance provided by HUD to these financially strapped borrowers,
                              over half would eventually lose their homes through foreclosure.6
                              Moreover, the Mortgage Assignment Program did not reduce HUD’s
                              foreclosure losses; rather, the program’s losses exceeded those that would
                              have occurred if the loans had gone immediately to foreclosure without

                              All single-family loans sold by HUD came with a loan sales agreement
                              requiring the loan purchasers and servicers to honor existing forbearance
                              agreements. The requirements contained in the loan sales agreements
                              varied, depending upon whether the sold loan was within or outside the
                              initial 36-month period after assignment to HUD. If less than 36 months
                              had passed since the loan was assigned to HUD, the forbearance agreement
                              could reduce or suspend monthly mortgage payments, depending on the
                              financial condition of the borrower. For a loan in which 36 months had
                              passed since it was assigned to HUD, the sales agreement requires that the
                              forbearance agreement stipulate a minimum monthly payment at least
                              equal to the payment required under the terms of the original loan
                              (including principal, interest, taxes, and insurance). After 36 months, the
                              mortgage payments could be more than the original amount--in order to
                              pay off past amounts due and bring the mortgage current sooner--if the
                              borrower’s financial information indicated that the borrower could afford
                              to make higher payments. There is no regulatory limit on the size of this
                              monthly payment. In addition, the servicer could extend the maturity date
                              of the loan for up to 10 years if the maximum payment that the borrower
                              could afford did not completely retire the borrower’s liability within the
                              original terms of the loan.

The Majority of Borrowers     Data on the disposition of loans were available for 58,012 of the 98,640
Whose Loans Have Been         single-family loans sold by HUD. These data show that, as of December 31,
                              1998, most of the homeowners whose loans were sold continued to own
Sold Are Current With Their
                              their homes. According to the company responsible for servicing these
Loan Payment or Have Paid     loans, it has worked with many borrowers to restructure their mortgage
Off Their Loans               debt so that most were able to restore their credit; reduce their past-due
                              interest; and, ultimately, bring the loan current. As shown in figure 1, 55
                              percent of this servicer’s loans are current under the original loan terms or
                              forbearance agreement terms; 14 percent have been paid off or refinanced;

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

                              Page 4                                        GAO/RCED-99-145 HUD’s Single-Family Loans

                           and 14 percent are delinquent, pending foreclosure, or in bankruptcy. Four
                           percent have been foreclosed, and the remaining 13 percent have had their
                           servicing transferred or have been resolved in some other way.

                           Figure 1: Status of 58,012 Sold Loans, as of December 31, 1998

                                                       Transferred or
                                                           7,691 (13% )
                                 Foreclosed                                                         Current
                                      2,072 (4% )                                                 31,690 (55% )

                               Paid off or
                                8,407 (14% )

                                               8,152 (14% )
                                       Delinquent, pending
                                    foreclosure, or bankruptcy
                           Source: GAO’s analysis of HUD’s data.

HUD Has Controls in        HUD’s compliance reviews and a toll-free telephone service are the primary
                           controls HUD uses to ensure that servicers comply with the borrower
Place to Monitor           protections provided under each loan sales agreement. HUD has employed
Servicers’ Compliance      these two controls to uncover numerous cases in which servicers were not
                           complying with borrower protections, and it has directed servicers to take
With Homeowner             corrective actions. According to HUD, servicers have taken actions to
Protections                correct the problems with protecting borrowers that were found through
                           compliance reviews and the toll-free telephone service. However, in some
                           cases, HUD’s records either do not show whether servicers took corrective
                           action or do not describe the action taken.

HUD Conducted Reviews of   Compliance reviews of the servicers of sold loans are undertaken by HUD’s
Loan Servicers             quality assurance reviewers at the direction of HUD headquarters. These
                           directives result from complaints to the Department’s toll-free telephone
                           line and from information provided to headquarters by field office staff.
                           The loan sales agreements serve as audit guidelines. These agreements

                           Page 5                                         GAO/RCED-99-145 HUD’s Single-Family Loans

require loan servicers to offer borrowers forbearance as required under the
now defunct Mortgage Assignment Program, including the following
actions: (1) within the initial 36-month period since assignment, reducing
or suspending mortgage payments on the basis of the borrower’s ability to
pay; (2) after the initial 36 months, setting mortgage payments equal to the
original mortgage payment, or more, if the borrower can afford to make
higher payments; (3) allowing borrowers in default under a forbearance
agreement to pay delinquent principal and interest (reinstate the
forbearance agreement) and avoid foreclosure; and (4) allowing borrowers
who are current under an expiring forbearance agreement to renew the
agreement for an additional period of time.

We reviewed six compliance reviews of companies that serviced sold loans.
These reviews involved four companies that, together, serviced about 60
percent of the single-family loans sold by HUD since 1994. 7 In letters
summarizing the results of these reviews, HUD reported numerous
instances in which servicers were not complying with borrower
protections. Specifically, HUD found, among other things, that two
servicers were not allowing borrowers to reinstate the loan once they were
in default and not allowing borrowers who were current with an expiring
forbearance plan to renew it for an additional period of time. In addition,
HUD found that all four servicers were increasing monthly mortgage
payments without any financial support showing that the borrower could
afford the higher payment--for two servicers, HUD cited this finding in both
the initial and subsequent reviews. Other problems identified through the
compliance reviews included pressuring the borrower to refinance,
harassing the borrower, and failing to employ prudent servicing practices.

Overall, in response to most findings, servicers agreed to change how they
service sold loans and/or took corrective actions on individual loans. For
example, after HUD informed one servicer that borrowers were not being
given the opportunity to reinstate their loan, the servicer responded that its
collection personnel would be made aware of the requirement and that the
requirement would be made part of the servicer’s collection procedures.
In another review, HUD found that the servicer increased the mortgage
payment without any analysis of the borrower’s financial condition. In

 HUD conducted a total of seven compliance reviews of servicers of sold single-family loans, six of
which were summarized in letters to the loan servicers. HUD did not prepare a written summary of the
remaining compliance review.

Page 6                                           GAO/RCED-99-145 HUD’s Single-Family Loans

                           response, the servicer agreed to begin documenting the financial analysis
                           upon which mortgage increases are based.

                           In several instances servicers agreed to take corrective actions on
                           individual loans in response to HUD’s findings. For example, for one
                           servicer, in six of the loans HUD reviewed, borrowers were not given the
                           opportunity to renew expired forbearance agreements. For five of the six
                           loans, the servicer agreed with the facts as presented by HUD and allowed
                           the borrowers to renew their forbearance agreements. For the remaining
                           loan, the servicer responded that the borrower had brought the loan
                           current. Thus, there was no need to renew the expired forbearance
                           agreement. This servicer also agreed to make changes in how it services
                           sold loans--allowing borrowers to renew their forbearance agreements--and
                           to communicate this requirement to its staff.

                           Servicers sometimes disagreed with the facts as presented by HUD and
                           took no action or were unresponsive. For example, in one of its reviews,
                           HUD found that for 10 borrowers, the servicer was requiring mortgage
                           payments in excess of what the borrower could afford to pay. However, the
                           servicer disagreed with HUD on the facts for 7 of the 10 borrowers,
                           responding that the borrowers were already on suspended or substantially
                           reduced mortgage payments. HUD is now gathering additional information
                           to substantiate its earlier findings with regard to these borrowers and other
                           issues and will present this information to HUD’s Mortgagee Review Board
                           to consider sanctions. For the remaining three borrowers, the servicer
                           agreed with the facts as presented by HUD and responded that the problem
                           was due to a computer system error.

HUD Provided a Telephone   In September 1996, when HUD held its third loan sale, it established a toll-
Complaints Service         free telephone complaint line and hired a contractor to answer the calls. To
                           ensure that borrowers were aware of the telephone complaint line, HUD
                           announced its existence to homeowners in its "goodbye letter.”8 HUD’s
                           contractor documents each call it receives and then transfers the
                           information to HUD’s field office in Tulsa, Oklahoma. HUD’s Tulsa staff are
                           responsible for contacting the borrower and, if necessary, the servicer, in
                           an attempt to resolve the complaint.

                               A “goodbye letter” informs homeowners that their loan will be included in an upcoming loan sale.

                           Page 7                                               GAO/RCED-99-145 HUD’s Single-Family Loans

We estimate that since it began operation, HUD’s complaint line has
received slightly under 6,900 telephone complaints or inquiries from
borrowers whose loans had been sold.9 This telephone service allows
borrowers to inquire about the status of their account or complain about
their servicer. Overall, HUD headquarters officials told us that about 90
percent of the calls received over its caller complaint line dealt with routine
requests for information, such as an account status, the reason their
particular loan was sold, or the reasons that the new servicer used business
practices that are different from HUD’s. On the basis of our review of a
random sample of 362 caller case files, we estimate10 that 1,083 of about
6,900 calls received involved serious complaints that loan servicers were
requiring too high a mortgage payment, demanding that the loan be brought
current, and/or threatening foreclosure.11 We categorized the remaining
calls as routine borrower requests for information.

One objective of a HUD-contracted study of the loan sales program was to
examine the type of inquiries and complaints that HUD had received on its
toll-free complaint line. According to this study, of the calls HUD received
through July 1998, about one-third concerned increases in required
monthly mortgage payments; about 40 percent were inquires about the
current or delinquent status of a loan and the caller’s rights with the new
private-sector servicer; and about 27 percent concerned specific amounts
owed or the servicer’s receipt of a payment.

However, according to HUD staff responsible for responding to calls, these
complaints often proved to be unwarranted. That is, the staff said,
borrowers often claimed some sort of grievance that did not prove to be
true when the staff researched the matter. For example, the telephone
service received numerous complaints on the amount required to pay off
mortgages because borrowers thought that their monthly mortgage
payments were always applied by servicers to pay off their original
mortgage debt. Often, however, these monthly payments were only
sufficient to pay interest. In other cases, borrowers did not provide
updated financial information that the servicers needed to substantiate the

 A HUD official estimates that there were about 4,800 calls logged and that an estimated 500 calls were
received before the call log was created.

10The   margin of error for this estimate, at the 95-percent confidence level, is +/- 264 complaints.

 One loan servicer is currently the subject of a class action lawsuit filed on behalf of about 2,000
borrowers to whom the servicer sent notices of intention to foreclose.

Page 8                                                 GAO/RCED-99-145 HUD’s Single-Family Loans

                      continuing need for forbearance. As a result, the servicers increased the
                      amount of payments or demanded full payment. Borrowers offered the
                      following reasons for not providing this information: (1) the tone in the
                      letters that the new servicer used was harsh or (2) they never read, or could
                      not understand, the letter. Finally, some borrowers asked the servicer for
                      a compromise sale (a forced buy-down); that is, they wanted HUD to
                      repurchase their loan from the new owner and sell the loan to them at the
                      compromise sale price. While this practice occurred in the past, it is not
                      allowed in the loan sales process.

                      According to a HUD official and information contained in HUD’s caller log,
                      almost all calls received by HUD have been resolved. However, for the
                      caller files we examined, we found insufficient information for us to
                      determine the final disposition of 40 percent of these serious complaints.12

Loan Sales Occurred   HUD has dramatically reduced its inventory of HUD-held single-family
                      loans since the loan sale program began. At the same time, total HUD
During a Period of    housing staffing has been reduced. Given the dramatic decline in HUD’s
Staffing Reductions   inventory of HUD-held loans and the elimination of the Mortgage
                      Assignment Program, it is reasonable to expect that HUD could reduce the
                      staffing devoted to servicing HUD-held loans. While we were unable to
                      obtain data on the staffing resources used to service HUD-held loans, the
                      total full-time-equivalent staff for asset management--which includes the
                      servicing of HUD-held loans--has declined from about 3,400 in fiscal year
                      1994 to an estimated 2,000 in fiscal 1998. Over two-thirds of this decline
                      was for full-time equivalent staff in field offices who were managing single-
                      family assets, and much of the decline occurred during 1997 and 1998.
                      Finally, asset management is continuing to undergo change.

                      A major reason for undertaking the loan sales program was to better use
                      limited staff resources by reducing the number of HUD-held loans, thereby
                      freeing staff to focus on managing HUD’s portfolio of insured loans. In
                      addition, according to HUD officials, private-sector companies are much
                      better able to service loans than are HUD staff. In fact, HUD’s housing staff
                      have many responsibilities other than servicing HUD-held loans and
                      managing the insured portfolio. Among these responsibilities are
                      monitoring lenders and quality assurance, managing and disposing of

                           The margin of error for this estimate at the 95-percent confidence level is +/- 14 percent.

                      Page 9                                                  GAO/RCED-99-145 HUD’s Single-Family Loans

property, and overseeing Section 8 housing assistance activities. Since
fiscal year 1991, HUD’s total housing staff has declined by over 40 percent.
Much of this decline has occurred since fiscal year 1994--the first year in
which HUD auctioned single-family loans and a period in which FHA
greatly modified its loan-processing functions. Specifically, HUD’s total
housing staff, as measured by full-time-equivalent staff, declined from
about 6,900 for fiscal year 1991 to about 6,000 for fiscal 1994 and to an
estimated 4,000 for fiscal 1998. (See fig. 2.)

Figure 2: Total Full-Time Equivalent Housing Staff, Fiscal Years 1990-98














                                      Fiscal year
Note: The data for fiscal year 1998 are based on a projection made as of August 31, 1998.
Source: HUD.

According to HUD, fiscal year 1998 was a year of transition, as staff and
organizations were realigned to implement HUD’s 2020 Management
Reform. Servicing HUD-held single-family loans was performed at seven
field offices in fiscal 1998. HUD plans to consolidate servicing functions in

Page 10                                           GAO/RCED-99-145 HUD’s Single-Family Loans

                  one location in fiscal 1999. According to the most recent financial
                  statement audit of FHA, however, because of staffing changes, workload
                  transitions, and the anticipation of selling the remaining notes, FHA was
                  less aggressive in undertaking foreclosure actions or other servicing
                  alternatives, such as workout plans or increased collection efforts. 13 As a
                  result, more of the HUD-held single-family loan portfolio became
                  delinquent during fiscal year 1998. Specifically, the portion of HUD-held
                  single-family loans that were delinquent increased from 57 percent in fiscal
                  year 1997 to 70 percent in fiscal 1998. In early 1999, HUD contracted for
                  functions involving the servicing of HUD-held loans and the management
                  and disposition of HUD-owned properties.

Agency Comments   We provided copies of a draft of this report to HUD for review and
                  comment. HUD agreed with the report’s findings and noted that it has
                  instructed the staff responsible for resolving telephone complaints to
                  maintain better records of how complaints are resolved and that it is
                  continuing to pursue instances in which it finds inappropriate loan
                  servicing. Overall, HUD affirmed the Department’s intent to continue its
                  efforts to ensure fair and equitable treatment of borrowers whose loans
                  were sold. HUD’s comments appear in appendix I.

Scope and         In preparing this report, we focused on five of HUD’s six single-family loan
                  sales.14 The loans sold through these five sales represented about 85
Methodology       percent of all the loans HUD sold from June 1994 through September 1997.
                  Nearly all of these loans were formerly in HUD’s Mortgage Assignment

                  First, to determine the current disposition of single-family loans that have
                  been sold, we collected information from the largest servicer of sold single-
                  family loans on the status of its loans as of December 31, 1998. This was
                  the only loan servicer that would agree to provide such data.

                  13See Federal Housing Administration, Audit of Fiscal Year 1998 Federal Basis Financial Statements,
                  Department of Housing and Urban Development, Office of Inspector General (Report: 99-FO-131-0002,
                  March 12, 1999).

                    The first HUD sale consisted of 15,212 HUD-held 221(g) (4) loans. These are performing loans that
                  are assigned to HUD in their twenty-first year by lenders, as previously allowed under the terms of FHA
                  mortgage insurance.

                  Page 11                                            GAO/RCED-99-145 HUD’s Single-Family Loans

Second, to identify what actions HUD has taken to ensure that loan
servicers abide by the borrower protections contained in loan sales
agreements, we interviewed HUD officials at headquarters in Washington,
D.C.; Quality Assurance staff in Atlanta, Georgia; and staff at the HUD field
office in Tulsa, Oklahoma, who are responsible for the toll-free borrower
phone line. We also reviewed HUD’s compliance reviews and the
correspondence between HUD and loan servicers that were the subject of
those reviews and examined HUD’s telephone complaint log of calls
received on its toll-free complaint line since 1996. For the estimated 6,900
of these calls received, we reviewed a random sample of 362 caller case
files in order to determine the nature of callers’ complaints and their
current status. We did not verify whether loan servicers who agreed to
make policy changes or take other corrective actions in response to HUD’s
findings actually made changes in the way they service loans.

Finally, to analyze changes in HUD’s staffing resources, we interviewed
headquarters officials responsible for overseeing the management of HUD’s
acquired assets and relied on staffing and workload data provided by the
Department. We conducted our review from July 1998 through May 1999 in
accordance with generally accepted government auditing standards.

We are providing copies of this report to Senator Connie Mack, the
Chairman of the Subcommittee on Economic Policy, Senate Committee on
Banking, Housing, and Urban Affairs; the Honorable Andrew M. Cuomo,
the Secretary of Housing and Urban Development; and other interested
parties. Copies will also be made available to others upon request.

Page 12                               GAO/RCED-99-145 HUD’s Single-Family Loans

If you or your staff have any questions about this report, please contact me
at (202) 512-7631. Major contributors to this report were Bill Bley, Pat
Doerning, Matt Scire, and Pat Valentine.

Judy A. England-Joseph
Director, Housing and Community
 Development Issues

Page 13                              GAO/RCED-99-145 HUD’s Single-Family Loans
Appendix I

Comments From the Department of Housing
and Urban Development                                              AppeIx

             Page 14       GAO/RCED-99-145 HUD’s Single-Family Loans
                   Appendix I
                   Comments From the Department of Housing
                   and Urban Development

(385777)   L
           ertet   Page 15                                   GAO/RCED-99-145 HUD’s Single-Family Loans
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