The requirements set forth in Mortgagee Letter 2013-04 became effective on June 3, 2013. For all forward mortgages (except for streamline refinance transactions of existing FHA loans) with case numbers assigned on or after April 1, 2013, annual MIP will increase. For all mortgages with case numbers assigned on or after June 3, 2013, the policies of identified, prior Mortgagee Letters governing automatic cancellation of annual MIP will be rescinded, and the exemption for annual MIP on mortgages with terms of 15 years or less and LTVs of less than or equal to 78 percent at origination will be removed. For more detail, please refer to our prior article on this subject. Note that FHA Commissioner Carol Galante issued a statement on June 3, in which she indicated that the FHA recognizes that the change in policy established by ML 2013-04 may cause additional loans to exceed HPML thresholds under Regulation Z. According to the statement, the FHA expects lenders to comply with all applicable requirements for loan origination, including HPML requirements.
