Lenders’ inconsistent eligibility requirements seem to be the most consistent thing we have seen with respect to the Federal Government’s HAFA (Home Affordable Foreclosure Alternatives) Program. The Federal Government seems to have taken notice.
On August 9, 2011, the Home Affordable Foreclosure Alternatives Program adopted certain policy guideline changes. The changes, we presume, are in response to concerns raised with respect to the unwillingness of lenders to publish their respective HAFA guidelines and requirements. Indeed, we have seen that each lender’s HAFA guidelines amounted to no more than a moving target, a target which changed frequently. That could now be a thing of the past.
The attached HAFA Update states that a servicer must now complete and post to its website a matrix that indentifies the servicer’s unique HAFA eligibility criteria and program rules. This matrix must be consistent with the lender’s HAFA Policy and any specific investor requirements.
All lenders are required to have their matrices posted no later than October 15, 2011. During this time period, we will keep abreast of each lender’s specific program rules and guidelines as they become available. It is our belief that in forcing lenders to publish these guidelines, lenders will be less able to make arbitrary changes to their HAFA guidelines. That could eventually lead to more reliability and certainty in the short sale approval process.