oversight

Union Federal Bank of Indianapolis, Supervised Direct Endorsement Lender; Fort Wayne, IN

Published by the Department of Housing and Urban Development, Office of Inspector General on 2005-04-07.

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

           AUDIT REPORT




     UNION FEDERAL BANK OF INDIANAPOLIS
   SUPERVISED DIRECT ENDORSEMENT LENDER

           FORT WAYNE, INDIANA

                 2005-CH-1009

                 APRIL 7, 2005




            OFFICE OF AUDIT, REGION V
                CHICAGO, ILLINOIS




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                                                               Issue Date
                                                                        April 7, 2005
                                                               Audit Report Number
                                                                            2005-CH-1009




TO:         John C. Weicher, Assistant Secretary for Housing-Federal Housing
               Commissioner and Chairman of Mortgagee Review Board, H


FROM:       Heath Wolfe, Regional Inspector General for Audit, 5AGA

SUBJECT: Union Federal Bank of Indianapolis, Supervised Direct Endorsement Lender;
           Fort Wayne, IN; Procedures and Controls Over Late Requests for
           Endorsement and Upfront Mortgage Insurance Premium Payments Were
           Improved

                                   HIGHLIGHTS

 What We Audited and Why

             We reviewed Union Federal Bank of Indianapolis (Union Federal) (also known as
             Union Federal Savings Bank of Indianapolis), a supervised lender approved to
             originate Federal Housing Administration mortgage loans under the U.S.
             Department of Housing and Urban Development’s (HUD) Single Family Direct
             Endorsement program. The review was part of the activities in our fiscal year
             2004 Annual Audit Plan. We selected Union Federal for audit because of its high
             late endorsement rate. Our review objectives were to determine whether Union
             Federal complied with HUD’s regulations, procedures, and instructions in the
             submission of late insurance endorsement requests and payment of upfront
             mortgage insurance premiums to HUD.

 What We Found


             Union Federal implemented improvements to its procedures and controls for late
             requests for endorsement and payment of upfront mortgage insurance premiums.
             Our audit tests of 662 loans identified only 12 (1.8%) that were improperly
             submitted for endorsement. Of the 12 loans, 10 remain Federal Housing


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            Administration-insured. These 10 loans increased the risk to the Federal Housing
            Administration insurance fund by $1,175,305 because the borrowers had not
            made six consecutive timely monthly payments at the time their loans were
            submitted to HUD and/or were behind on their mortgage payments. Union
            Federal also paid penalties for not paying upfront mortgage insurance premiums
            in a timely manner for 272 loans of the 5,415 total loans subject to HUD’s upfront
            mortgage insurance premium requirements. The staff of Union Federal’s
            authorized agent was not adequately trained or was not aware of HUD’s
            requirements regarding late requests for endorsement. In addition, Union
            Federal’s authorized agent did not always pay upfront mortgage insurance
            premiums due to an automation problem and its lack of adequate monitoring of
            the wholesale and retail areas involved in processing Federal Housing
            Administration loans.

What We Recommend

            We recommend that HUD’s Assistant Secretary for Housing-Federal Housing
            Commissioner and Chairman of the Mortgagee Review Board

        •   Require Union Federal to indemnify HUD for any future losses on nine loans with a
            total mortgage value of $965,777.

        •   Require Union Federal to reimburse HUD for any future loss for a claim on one
            insured loan (with a total mortgage value of $197,402) once the associated
            property is sold.

            For each recommendation without a management decision, please respond and
            provide status reports in accordance with HUD Handbook 2000.06, REV-3. Please
            furnish us copies of any correspondence or directives issued because of the audit.

Auditee’s Response


            We provided the results of our late endorsement and loan file reviews to Union
            Federal’s authorized agent, Waterfield Financial Corporation, during the review.
            We also provided our discussion draft audit report to Waterfield’s Senior Vice
            President of Credit Risk and HUD’s staff on March 18, 2005. We conducted an
            exit conference with Waterfield’s Senior Vice President on March 28, 2005.

            Waterfield Financial Corporation’s Senior Vice President of Credit Risk provided
            written comments to the discussion draft audit report on April 1, 2005, that agreed
            with our findings. The complete text of Waterfield’s written response including a
            five-page attachment, and our evaluation of that response, can be found in
            appendix B of this report.




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                              TABLE OF CONTENTS

Background and Objectives                                                            4

Results of Audit

        Finding: Union Federal Improved Procedures and Controls Over Late Requests   5
                 for Endorsement and Upfront Mortgage Insurance Premium Payments

Scope and Methodology                                                                8

Internal Controls                                                                    9

Follow up on Prior Audits                                                            11

Appendixes
   A.   Schedule of Unsupported Costs and Funds To Be Put to Better Use              12
   B.   Auditee Comments and OIG’s Evaluation                                        13
   C.   Federal Requirements                                                         21
   D.   Schedule of Late Endorsements                                                23
   E.   Late Payments of Upfront Mortgage Insurance Premiums Between May 1, 2002,    24
        and April 30, 2004




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                      BACKGROUND AND OBJECTIVES

The U.S. Department of Housing and Urban Development (HUD) insures single-family
mortgages under various sections of the National Housing Act. HUD’s mortgage programs
provide mortgage insurance on loans for new or existing homes, condominiums, manufactured
housing, and housing rehabilitation and for reverse mortgages to elderly homeowners.

In May 1990, HUD approved Union Federal Bank of Indianapolis (Union Federal) under its
previous name, Union Federal Savings Bank of Indianapolis, as a supervised direct endorsement
lender. In February 2000, “Savings” was dropped from the Bank’s name, and it officially
became Union Federal Bank of Indianapolis. Union Federal’s corporate office is located in
Indianapolis, IN. As a direct endorsement lender, Union Federal determines that the proposed
mortgage is eligible for insurance under the applicable program regulations and submits the required
documents to HUD without its prior review of the origination and closing of the mortgage loan.
Union Federal is responsible for complying with all applicable HUD regulations and handbook
instructions.

On July 16, 1990, HUD approved Waterfield Financial Corporation as an authorized agent for
Union Federal. As an authorized agent, Waterfield Financial Corporation processes,
underwrites, or submits insurance endorsement requests on behalf of Union Federal under a
principal-agent relationship. Union Federal’s mortgage payment servicing is performed by its
parent company, Waterfield Mortgage Company. Both Union Federal’s authorized and servicing
agents operate their businesses in Fort Wayne, IN. Union Federal is the sponsor of 406 loan
correspondents and acting agent for six principals originating or processing Federal Housing
Administration loans.

We reviewed Union Federal as part of the activities in our fiscal year 2004 Annual Audit Plan.
We selected Union Federal for review because of its high late endorsement rate of 32 percent
during the period from May 1, 2002, through April 30, 2004. During this same period, Union
Federal sponsored 5,760 Federal Housing Administration loans totaling more than $700 million.

Our review objectives were to determine whether Union Federal complied with HUD’s
regulations, procedures, and instructions in the submission of late insurance endorsement
requests and payment of upfront mortgage insurance premiums to HUD.




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                                RESULTS OF AUDIT


Finding: Union Federal Improved Procedures and Controls Over Late
  Requests for Endorsement and Upfront Mortgage Insurance Premium
                             Payments
Union Federal implemented improvements to its procedures and controls for late requests for
endorsement and payment of upfront mortgage insurance premiums to fully comply with HUD’s
requirements. However, before the procedures and controls were strengthened, Union Federal
improperly submitted 12 loans for late endorsement. Of the 12 loans, 10 remain Federal
Housing Administration-insured. These 10 loans increased the risk to the Federal Housing
Administration insurance fund by $1,175,305 because the borrowers had not made six
consecutive timely monthly payments at the time their loans were submitted to HUD and/or were
behind on their mortgage payments. Union Federal also paid penalties for not paying upfront
mortgage insurance premiums in a timely manner for 272 loans. The staff of Union Federal’s
authorized agent was not adequately trained or was not aware of HUD’s late endorsement
requirements. In addition, Union Federal’s authorized agent did not pay upfront mortgage
insurance premiums in a timely manner due to an automation problem and its lack of adequate
monitoring of the wholesale and retail areas involved in processing Federal Housing
Administration loans.



 Union Federal’s Authorized
 Agent Took Corrective Actions


              In January 2005, Union Federal’s authorized agent, Waterfield Financial
              Corporation, improved its procedures and controls over the submission of loans
              for late requests for endorsement.

              Waterfield Financial Corporation restructured its Government Insuring
              Department by adding an experienced direct endorsement underwriter to manage
              the Department, and train and supervise staff involved in the processing of
              Federal Housing Administration loans for late requests for endorsement. In
              February 2005, the newly hired underwriter started providing on-the-job training
              to Government Insuring Department staff on HUD’s loan endorsement
              requirements. Currently, Waterfield Financial Corporation is developing a formal
              training course that emphasizes how to properly read borrowers’ payment
              histories and what HUD requires regarding late requests for endorsement. The
              on-the-job training, adequate supervision, and formal training should provide
              reasonable assurance that Waterfield Financial Corporation’s staff follows HUD’s
              late endorsement requirements when submitting loans on Union Federal’s behalf.



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           In addition, after May 2004, Waterfield Financial Corporation began providing
           adequate monitoring of loan deficiencies shown in its internally generated reports
           and acted on these deficiencies quickly. It also became more aware of issues
           regarding loans with upfront mortgage insurance premiums and addressing such
           issues in a timely manner. Further, Waterfield Financial Corporation’s
           automation problem relating to payment of upfront mortgage insurance premiums
           was resolved when the programming of its computer systems used for
           electronically paying upfront mortgage insurance premiums was corrected.
           Because of the corrected programming and the improved procedures and controls
           over the payment of upfront mortgage insurance premiums, Waterfield Financial
           Corporation’s late payments of upfront insurance premiums decreased from an
           average of 5 percent in 2003 to 2 percent from May to December 2004. For the
           month of January 2005, Waterfield Financial Corporation had only one late
           payment out of the 175 loans with upfront insurance premiums.


Union Federal Improperly
Submitted 12 Late Requests for
Endorsement


           Our analysis of the mortgage payment histories provided by Union Federal,
           HUD’s case binders, and the endorsement data from HUD’s systems showed that
           Union Federal improperly submitted 12 late requests for insurance endorsement
           (see appendix D in this report).

           After endorsement, 2 of the 12 loans were paid in full and no longer represent a
           risk to the Federal Housing Administration insurance fund. Because these loans
           are no longer insured, we did not conduct further research or compliance testing.
           The remaining 10 loans are still insured and pose a risk to the insurance fund as
           follows:

           •   For one loan (case number 261-8337062) having an original mortgage amount
               totaling $197,402, HUD paid a claim of $209,528 with an indeterminate loss
               as of March 18, 2005. HUD cannot identify the loss until the property is sold.
               This loan represents a risk to the insurance fund.

           •   The insurance was terminated without a claim on another loan (case number
               261-8513340) with an original mortgage amount totaling $110,224, which
               was streamline-refinanced to another Federal Housing Administration loan.
               Because Union Federal improperly submitted the loan for insurance
               endorsement, the improper endorsement also applies to the refinanced loan.
               Therefore, we included the loan as an improperly endorsed loan.

           •   Eight loans hold active Federal Housing Administration insurance with
               $855,553 in total original mortgage amounts.



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             Appendix C of this report provides details of Federal requirements regarding late
             requests for insurance endorsement.


 Union Federal Failed to Pay
 Insurance Premiums in a
 Timely Manner


             Between May 1, 2002, and April 30, 2004, Union Federal sponsored 5,760 loans.
             Of the 5,760 loans, 5,415 were subject to HUD’s requirements regarding payment
             of upfront mortgage insurance premiums. Of the 5,415 loans, Union Federal did
             not pay the upfront mortgage insurance premiums on time for 272 loans. Union
             Federal paid HUD the insurance premiums 16 to 824 days after closing. We did
             not question these loans because Union Federal has already paid the upfront
             mortgage insurance premiums, late charges, and interests on the 272 loans (see
             appendix E of this report). HUD requires lenders to pay the upfront mortgage
             insurance premiums 15 days after closing a loan. It also requires lenders to pay a
             4-percent late charge if the payment of upfront mortgage insurance premiums is
             made later than 15 days after closing plus interest if the payment is made later
             than 30 days after closing.


Recommendations


             We recommend that HUD’s Assistant Secretary for Housing-Federal Housing
             Commissioner and Chairman of the Mortgagee Review Board require Union
             Federal to

             1A.    Indemnify HUD for any future losses on nine loans with a total mortgage
                    value of $965,777 ($855,553 plus $110,224).

             1B.    Reimburse HUD for any future losses from a $209,528 claim paid on one
                    insured loan (with a total mortgage value of $197,402) once the associated
                    property is sold.




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                        SCOPE AND METHODOLOGY

We conducted the review at HUD’s Columbus Field Office and Union Federal’s servicing and
authorized agents’ offices in Fort Wayne, IN. We performed our review work between October
26, 2004, and February 28, 2005. To accomplish our review objectives, we interviewed HUD’s
staff and Union Federal’s servicing and authorized agents’ staff. We analyzed loan data in
HUD’s Single-Family Data Warehouse system. We reviewed and tested Union Federal’s
authorized agent’s policies, procedures, and controls regarding submission of loans for late
endorsement and payment of upfront mortgage insurance premiums. We also reviewed HUD’s
case binders for 49 Federal Housing Administration-insured loans statistically selected at random
out of a universe of 662 loans Union Federal closed between May 2002 and April 2004, and
submitted to HUD more than 66 days after closing.

We chose the 662 loans using computer-assisted audit techniques, including the ACL computer
program. In addition, we relied in part on data maintained in HUD’s Single Family Data
Warehouse and Neighborhood Watch systems. We did not perform a detailed analysis of the
reliability of HUD’s Single Family Data Warehouse or Neighborhood Watch data.

The review covered the period between May 2002 and April 2004. We conducted the review in
accordance with generally accepted government auditing standards.




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                              INTERNAL CONTROLS

Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being achieved:

   •   Effectiveness and efficiency of operations,
   •   Reliability of financial reporting, and
   •   Compliance with applicable laws and regulations.

Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance.



 Relevant Internal Controls


              We determined the following internal controls were relevant to our review
              objectives:

              •       Program Operations – Policies and procedures that management has
                      implemented to reasonably ensure that a program meets its objectives.

              •       Validity and Reliability of Data – Policies and procedures that
                      management implemented to reasonably ensure that valid and reliable data
                      are obtained, maintained, and fairly disclosed in reports.

              •       Compliance with Laws and Regulations – Policies and procedures that
                      management implemented to reasonably ensure that resource use is
                      consistent with laws and regulations.

                  •   Safeguarding Resources – Policies and procedures that management has
                      implemented to reasonably ensure that resources are safeguarded against
                      waste, loss, and misuse.

              We assessed the relevant controls identified above.

              A significant weakness exists if internal controls do not provide reasonable
              assurance that the process for planning, organizing, directing, and controlling
              program operations will meet the organization’s objectives.




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Significant Weaknesses


           Based on our review results, we believe the following items are significant
           weaknesses:

           •      Program Operations – Although Union Federal did not always submit loans
                  for late endorsement and pay upfront mortgage insurance premiums in
                  accordance with HUD’s requirements, it has modified its procedures and
                  controls to ensure its program operations comply with HUD’s requirements
                  (see finding).

           •      Validity and Reliability of Data – Union Federal has changed its policy to
                  provide adequate monitoring of loan deficiencies shown in its internally
                  generated reports and acted on these deficiencies quickly to ensure the
                  validity, reliability, and completeness of loan documents (see finding).

           •      Compliance with Laws and Regulations – Although Union Federal did not
                  always submit loans for late endorsement and pay upfront mortgage
                  insurance premiums in accordance with HUD’s requirements, it has
                  modified its procedures and controls to ensure it complies with laws and
                  HUD’s regulations (see finding).

           •      Safeguarding Resources – Union Federal improperly submitted 12 loans
                  with mortgages totaling more than $1 million for insurance endorsement.
                  The improper submissions increased the risk to the Federal Housing
                  Administration insurance fund (see finding).




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                       FOLLOWUP ON PRIOR AUDITS

This was the first audit of Union Federal by HUD’s Office of Inspector General (OIG).

The last two independent auditor’s reports for Union Federal covered the years ending December
31, 2002, and December 31, 2003. Both reports resulted in no findings.

Between June and July 2003, HUD’s Philadelphia Homeownership Center, Quality Assurance
Division, conducted a desk review of loans that Union Federal originated within the jurisdiction
of HUD’s field offices in Grand Rapids, MI, and Columbus, OH. The review resulted in two
findings relating to the loan origination process. Union Federal resolved the two findings, and
HUD closed the review in December 2003.




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                                    APPENDIXES

Appendix A

               SCHEDULE OF UNSUPPORTED COSTS
              AND FUNDS TO BE PUT TO BETTER USE

                  Recommendation         Unsupported       Funds To Be Put
                      Number                 1/            to Better Use 2/
                         1A                                    $965,777
                         1B                 $209,528
                        Totals              $209,528           $965,777


1/   Unsupported costs are costs charged to a HUD-financed or insured program activity and
     eligibility cannot be determined at the time of the audit. The costs are not supported by
     adequate documentation or there is a need for a legal or administrative determination on
     the eligibility of the cost. Unsupported costs require a future decision by HUD program
     officials. This decision, in addition to obtaining supporting documentation, might
     involve a legal interpretation of Departmental policies and procedures.

2/   “Funds to be put to better use” are quantifiable savings that are anticipated to occur if an
     OIG recommendation is implemented, resulting in reduced expenditures at a later time
     for the activities in question. This includes costs not incurred, deobligation of funds,
     withdrawal of interest, reductions in outlays, avoidance of unnecessary expenditures,
     loans and guarantees not made, and other savings.




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Appendix B

        AUDITEE COMMENTS AND OIG’S EVALUATION


Ref to OIG Evaluation   Auditee Comments




Comment 1




Comment 2




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Ref to OIG Evaluation                Auditee Comments




Comment 3




                        OIG Evaluation of Auditee Comments




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Ref to OIG Evaluation   Auditee Comments




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Ref to OIG Evaluation   Auditee Comments




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Ref to OIG Evaluation   Auditee Comments




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Ref to OIG Evaluation   Auditee Comments




Comment 3




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Ref to OIG Evaluation   Auditee Comments




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Ref to OIG Evaluation                    Auditee Comments



Comment 1     Union Federal’s authorized agent, Waterfield Financial Corporation, agreed to
              indemnify HUD for any future losses on nine loans with a total mortgage value
              of $965,777, and reimburse HUD for any future losses from a $209,528 claim
              paid on one insured loan once the associated property is sold.

Comment 2     We recognized that Waterfield Financial Corporation’s reorganized its
              Government Insuring Department by adding an experienced direct
              endorsement underwriter to manage its Department, and is training and
              supervising its staff involved in the processing of Federal Housing
              Administration loans for late requests for endorsement

Comment 3     We reviewed Waterfield Financial Corporation’s procedures and controls in its
              revised quality control plan. The procedures and controls appear adequate,
              and if fully implemented, should provide reasonable assurance that Waterfield
              Financial Corporation’s staff follows HUD’s late endorsement requirements
              when submitting loans on Union Federal’s behalf.




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Appendix C
                          FEDERAL REQUIREMENTS

According to 24 CFR [Code of Federal Regulations] 203.255(b), for applications for insurance
involving mortgages originated under the Direct Endorsement program, the lender shall submit
to the Secretary of Housing and Urban Development, within 60 days after the date of closing of
the loan or such additional time as permitted by the Secretary, properly completed
documentation and certifications.

HUD Handbook 4165.1, REV-1, “Endorsement for Insurance for Home Mortgage Programs
(Single Family),” dated November 30, 1995, chapter 3, section 3-1(A), states that late requests
for endorsement procedures apply if

   1. The loan is closed after the firm commitment,
   2. The direct endorsement underwriter’s approval expires, and/or
   3. The mortgage is submitted to HUD for endorsement more than 60 days after closing.

Section 3-1(B) states that a loan request for endorsement from the lender must include

   (1) An explanation for the delay in submitting for endorsement and actions taken to prevent
       future delayed submissions.

   (2) A certification that the escrow accounts for taxes, hazard insurance, and mortgage
       insurance premiums are current and intact except for disbursements which may have been
       made from the escrow accounts to cover payments for which the accounts were
       specifically established.

   (3) A payment ledger that reflects the payments received, including the payment due for the
       month in which the case is submitted if the case is submitted after the 15th of the month.
       For example, if the case closed February 3 and the case is submitted April 16, the
       payment ledger must reflect receipt of the April payment even though the payment is not
       considered delinquent until May 1. Payments under the mortgage must not be delinquent
       when submitted for endorsement.

                    (a) The lender must submit a payment ledger for the entire period from the
                        first payment due date to the date of the submission for endorsement.
                        Each payment must be made in the calendar month due.
                    (b) If a payment is made outside the calendar month due, the lender cannot
                        submit the case for endorsement until six consecutive payments have
                        been made within the calendar month due.

   (4) A certification that the lender did not provide the funds to bring the loan up-to-date or to
       affect the appearance of an acceptable payment history.

Mortgagee Letter 2004-14, “Late Request for Endorsement Procedures,” clarifies procedures for
mortgage lenders when submitting mortgage insurance case binders to the Federal Housing
Administration for endorsement beyond the 60-day limit following closing. It replaces the


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instructions found in the section “Late Request for Endorsement,” contained in chapter 3 of
HUD Handbook 4165.1, REV-3.

A request for insurance is considered “late” and triggers additional documentation whenever the
binder is received by HUD more than 60 days after the mortgage loan settlement or funds
disbursement, whichever is later.

If HUD returns the case binder to the lender by issuing a notice of rejection (or a later notice of
rejection), HUD’s Homeownership Center must receive the reconsideration request for insurance
endorsement within the original 60-day window or 30 days from the issue date of the original
notice of rejection, whichever is greater.

When submitting a late request for endorsement, in addition to including a payment history or
ledger, the mortgage lender is required to include a certification, signed by the representative of
that lender on company letterhead, which includes the lender’s complete address and telephone
number. This certification must be specific to the case being submitted (i.e., identify the Federal
Housing Administration case number and the name(s) of the borrower(s)) and state that

   1) All mortgage payments due have been made by the mortgagor before or within the month
      due. If any payments have been made after the month due, the loan is not eligible for
      endorsement until six consecutive payments have been made before or within the
      calendar month due.

   2) All escrow accounts for taxes, hazard insurance, and mortgage insurance premiums are
      current and intact, except for disbursements that may have been made to cover payments
      for which the accounts were specifically established.

   3) The mortgage lender did not provide the funds to bring the loan up-to-date or keep the
      loan current or to bring about the appearance of an acceptable payment history.




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Appendix D

                SCHEDULE OF LATE ENDORSEMENTS



                     Original        Unpaid
                     Mortgage       Principal    Closing Endorsement Insurance
         Case Number Amount         Balance       Date      Date       Status
         262-1405189   $104,975     $107,632     5/10/2002    7/16/2002   A
         197-2838362    159,165      157,268      7/1/2002   3/14/2003    T
         431-3727603     43,293       42,777     7/30/2002    12/4/2002   T
         441-6957849     45,304       44,326      9/6/2002   2/27/2003    A
         031-3012422     85,821       84,205      1/2/2003   11/28/2003   A
         261-8337062    197,402      196,499     1/20/2003   4/28/2003    C
         151-6988478    112,146       96,200      2/5/2003    4/23/2003   A
         093-5516725     81,717       80,001     4/30/2003   1/26/2004    A
         261-8513340    110,224      108,226     6/20/2003   11/26/2003   R
         045-6175724    122,743      120,082     7/2/2003    10/8/2003    A
         111-1145117    177,620      174,023      7/7/2003   12/23/2003   A
         151-7345294    125,227      123,219     9/25/2003    2/4/2004    A
            Totals     $1,365,637   $1,334,458



Legend

A = Active
C = Terminated with a claim
T = Terminated without claims
R = Streamline-refinanced




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Appendix E

 LATE PAYMENTS OF UPFRONT MORTGAGE INSURANCE
                   PREMIUMS
       BETWEEN MAY 1, 2002, AND APRIL 30, 2004



                                                        Percentage
                            Number of Late Number of       of Late
                               Upfront     Loans With     Upfront
                              Mortgage       Upfront     Mortgage
                              Insurance     Mortgage     Insurance
                               Premium      Insurance     Premium
                   Month      Payments     Premiums      Payments
             May 2002             10           258         3.88%
             June 2002            11           221         4.98%
             July 2002             7           202         3.47%
             August 2002          10           266         3.76%
             September 2002        9           212         4.25%
             October 2002          9           212         4.25%
             November 2002         7           195         3.59%
             December 2002        21           172         12.21%
             January 2003          7           170         4.12%
             February 2003         3           148         2.03%
             March 2003           10           257         3.89%
             April 2003           14           322         4.35%
             May 2003             19           293         6.48%
             June 2003            44           275         16.00%
             July 2003            26           248         10.48%
             August 2003          12           191         6.28%
             September 2003        3           225         1.33%
             October 2003          4           215         1.86%
             November 2003         6           171         3.51%
             December 2003         7           192         3.65%
             January 2004          5           133         3.76%
             February 2004         9           214         4.21%
             March 2004            6           317         1.89%
             April 2004           13           306         4.25%
                   Totals        272          5,415         5.02%




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