www.cbo.gov

CONGRESSIONAL BUDGET OFFICE

U.S. Congress

Washington, DC 20515

July 19, 2006

Honorable Jeb Hensarling

U.S. House of Representatives

Washington, DC 20515

Dear Congressman:

According to the federal budget, the subsidy cost of the Federal Housing Administration’s

(FHA’s) Mutual Mortgage Insurance (MMI) program is negative. That is, under the budget

accounting rules specified in the Federal Credit Reform Act of 1990 (FCRA), the program’s

activities are estimated to produce a net gain to the government, excluding its administrative

costs. The President’s budget for fiscal year 2007, for example, projects net income of 37 cents

for each $100 of guaranteed loans originated that year. However, studies by the Congressional

Budget Office (CBO) indicate that the current budget rules tend to understate the cost of federal

credit programs.

In response to your request of June 14, 2006, CBO has compared the cost of single-family

mortgage insurance offered by FHA as reported in the budget with the cost of comparable

insurance in private markets. The competitiveness of the market for private mortgage insurance

suggests that quoted prices are good approximations of the minimum cost of providing such

insurance. Therefore, the differences between market prices and premiums charged by FHA

indicate the actual cost to the government of federal mortgage insurance. That comparison yields

the following conclusions:

 Budget accounting understates the subsidy cost of credit programs by excluding the cost of

market risk and displaying administrative expenses separately. (Subsidy costs are recognized

up front as loans are originated; administrative expenses are included in the budget as they

are paid each year.) The result is a budgetary bias in favor of credit programs relative to other

types of spending programs.

 FHA’s Mutual Mortgage Insurance program imposes costs on the government and taxpayers.

On the basis of market prices for private mortgage insurance, the subsidy cost of the FHA

insurance is between 2 percent and 5 percent of the amount of insured loans, CBO estimates.

(However, the accounting rules specified in FCRA, which indicate a net gain to the

government from providing such insurance, govern federal budget estimates.)

 Some current proposals for increasing the volume of FHA insurance would increase the

government’s costs for that program.
Honorable Jeb Hensarling

Page 2

The details of CBO’s analysis are contained in the attachment to this letter. I hope that you find

the analysis useful. The staff contacts for this work are Marvin Phaup and Susanne Mehlman,

who can be reached at (202) 226-2640 and (202) 226-2860, respectively.

Sincerely,

Donald B. Marron

Acting Director

Attachment

cc: Honorable Jim Nussle, Chairman

Honorable John M. Spratt Jr., Ranking Member

House Committee on the Budget

Honorable Michael G. Oxley, Chairman

Honorable Barney Frank, Ranking Member

House Committee on Financial Services

Honorable Robert W. Ney, Chairman

Honorable Maxine Waters, Ranking Minority Member

Subcommittee on Housing and Community Opportunity

House Committee on Financial Services

Honorable Judd Gregg, Chairman

Honorable Kent Conrad, Ranking Member

Senate Committee on the Budget

Honorable Richard C. Shelby, Chairman

Honorable Paul S. Sarbanes, Ranking Member

Senate Committee on Banking, Housing, and Urban Affairs

Honorable Wayne Allard, Chairman

Honorable Jack Reed, Ranking Member

Subcommittee on Housing and Transportation

Senate Committee on Banking, Housing, and Urban Affairs
Assessing the Government’s Costs for

Mortgage Insurance Provided by the

Federal Housing Administration

July 19, 2006

The Congress of the United States ■ Congressional Budget Office
Note

The Congressional Budget Office’s (CBO’s) analysis was prepared by Marvin

Phaup and Susanne Mehlman under the supervision of Robert Dennis of the

Macroeconomic Analysis Division and Robert Sunshine of the Budget Analysis

Division. Deborah Lucas of Northwestern University provided helpful comments

and suggestions. (The assistance of an external reviewer implies no responsibility

for the final product, which rests solely with CBO.)
According to the federal budget, the subsidy cost of the Federal Housing

Administration’s (FHA’s) Mutual Mortgage Insurance (MMI) program is

negative. That is, under the budget accounting rules specified in the Federal

Credit Reform Act of 1990 (FCRA), the program’s activities are estimated to

produce a net gain to the government, excluding its administrative costs. The

President’s budget for fiscal year 2007, for example, projects net income of 37

cents for each $100 of guaranteed loans originated that year. However, studies by

the Congressional Budget Office (CBO) indicate that the current budget rules tend

to understate the cost of federal credit programs.

At the request of Congressman Jeb Hensarling, CBO has compared the cost of

single-family mortgage insurance offered by FHA as reported in the budget with

the cost of comparable insurance in private markets. The competitiveness of the

market for private mortgage insurance suggests that quoted prices are good

approximations of the minimum cost of providing such insurance. Consequently,

the differences between market prices and premiums charged by FHA indicate the

actual cost to the government of providing federal mortgage insurance. That

comparison yields the following conclusions:

 Budget accounting understates the subsidy cost of credit programs by

excluding the cost of market risk and displaying administrative expenses

separately. (Subsidy costs are recognized up front as loans are originated;

administrative expenses are included in the budget as they are paid each year.)

The result is a budgetary bias in favor of credit programs relative to other

types of spending programs.

 FHA’s Mutual Mortgage Insurance program imposes costs on the government

and taxpayers. On the basis of market prices for private mortgage insurance,

the subsidy cost of the FHA insurance is between 2 percent and 5 percent of

the amount of insured loans, CBO estimates. (However, the accounting rules

specified in FCRA, which indicate a net gain to the government from

providing such insurance, govern federal budget estimates.)

 Some current proposals for increasing the volume of FHA insurance would

increase the government’s costs for that program.

FHA Single-Family Mortgage Insurance: An Overview

Since its inception in 1934, FHA has provided mortgage insurance for singlefamily and multifamily homes and now also provides it for manufactured homes

and hospitals. The insurance affords lenders with protection against losses from

defaults and increases the availability of funds for higher-risk borrowers. In

particular, FHA’s Mutual Mortgage Insurance program, the federal government’s

largest mortgage insurance program, is aimed at extending access to home
2

ownership to those who lack the savings, credit history, or income to qualify for

an unguaranteed, or conventional, mortgage. Under that program, FHA provides

insurance on 30-year and 15-year fixed- and adjustable-rate amortizing mortgages

for home purchases or refinancing.

FHA charges borrowers both up-front and annual fees for the service. Current law

authorizes an initial fee of up to 2.25 percent of the loan amount and an annual fee

of up to 0.55 percent of the unpaid balance. At present, the premium is a one-time

fee of 1.5 percent and an annual fee of 0.5 percent. (The annual fee ceases when

the loan balance is reduced to 78 percent of the initial amount.) FHA also requires

a down payment of at least 3 percent of the purchase price.1

To target the program to low- and moderate-income borrowers, authorizing

legislation limits the dollar value of the mortgages that may be insured. Those

limits vary by geographic region, depending on the ceilings that the governmentsponsored enterprises for housing—Fannie Mae and Freddie Mac––set for

conforming mortgages; appreciation in house prices; and the cost of living for an

area. Currently, the limit in most areas is $200,160, but in some high-cost areas,

FHA can insure loans up to $362,790.

In fiscal year 2005, FHA guaranteed about $58 billion in new loans, which is

down sharply from the $147 billion extended in 2003 (see Figure 1). Although

that drop seems precipitous, FHA has seen a long-term decline in its share of

single-family mortgages since the mid-1990s, when the agency insured about 15

percent of all such mortgages. Its current share is about 5 percent (see Figure 2).

The decline in the volume of new business, combined with increases in losses

from defaults, has significantly reduced the net gains shown in the federal budget

from new business. Insurance issued in fiscal year 2003, for example, is now

estimated to have a net negative subsidy (that is, net income in the budget) of $1.5

billion. For loans guaranteed in fiscal year 2005, the estimated net income is $123

million.

FHA’s basic insurance is directed at a segment of the market that is shrinking and

becoming less dependent on the government for access to mortgage financing. In

part, that situation has arisen because private lenders have increased their

offerings for low-down-payment and higher-risk mortgages. In addition, FHA is

restricted in the range of mortgage types that it can insure: 30- and 15-year

amortizing mortgages of limited size with a minimum down payment of 3 percent

of the purchase price. Private mortgage insurers, by contrast, have recorded

especially rapid growth in coverage for loans with down payments of less than 3

percent; mortgages of amounts higher than FHA’s limits; deferred principal/

1. The ratio of the loan amount to house value may exceed 97 percent, however, because the up-front

fee and first-year premium can be financed as part of the insured loan.
3

Figure 1. 

FHA’s Guarantees of New Mortgages, 2000 to 2007 

(Billions of dollars) 

2000 2001 2002 2003 2004 2005 2006 2007

0

20

40

60

80

100

120

140

160

Source: Congressional Budget Office based on data from the Federal Housing Administration. 

Note: The amount for 2006 is estimated; the amount for 2007 is projected. 

payment or interest-only mortgages; and adjustable-rate mortgages in which the

borrower has an option to pay only a portion of the amount due each month. FHA

may also suffer from a perception that the quality of its service is uneven.2

Limitations of the Current Budgetary Treatment of FHA

Mortgage Insurance

In the federal budget, FHA’s loan guarantee programs are considered

discretionary and thus require appropriation action each year to establish a dollarvolume limit for each program and to provide an appropriation of subsidy costs

for those programs whose estimated subsidy is positive. Subsidy costs are the

present value of the government’s projected cash flows from guaranteed loans

disbursed in a fiscal year. Administrative expenses for the programs are separately

subject to appropriation; such expenses are recorded each year as they are paid,

rather than up front as loans are originated. They are not counted against the

appropriation for subsidy costs.

2. See the statements of Regina M. Lowrie, Mortgage Bankers Association, and Jerry Howard,

National Association of Home Builders, before the Subcommittee on Housing and Community

Opportunity, House Committee on Financial Services (April 5, 2006).
4

Figure 2. 

FHA’s Share of the Market for Single-Family Mortgages, 

1992 to 2004 

(Percent) 

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

0

2

4

6

8

10

12

14

16

Source: Congressional Budget Office based on data from Forrest Pafenberg, Office of Federal Housing 

Enterprise Oversight. 

The primary effect of loans and guarantees on the federal budget is the subsidy

costs (or savings) calculated according to the requirements of the Federal Credit

Reform Act of 1990.3 That law specifies the rules for estimating the cost of direct

loans and loan guarantees, including mortgage insurance. It defines the subsidy

cost of guarantees as the net present value of the government’s cash flows from

fees and defaults, net of recoveries. FCRA’s specified method of calculating

subsidies for federal credit, however, omits some costs even though they can be

major contributors to the total cost of credit.

The FCRA rules for calculating subsidies include the cost of expected losses from

defaults, but they do not value those losses the way markets do––by including a

cost for uncertainty and risk. The budget measures expected, or average, losses. In

doing so, it assigns the same cost to an expected loss of 25 percent of principal

that is certain to occur as it does to a loss with the same expected value but for

which the realized loss can range from zero to 100 percent. If markets were

indifferent to whether losses in any particular year were above or below the

expected value, the budget measure would be adequate. But losses on FHA loans

3. In the case of FHA, administrative expenses for fiscal year 2007 are projected to outweigh subsidy

costs––owing to a low projected volume of new insurance, a low negative subsidy rate, and a large

volume of existing guarantees that must be serviced.
5

(and loans under other federal credit programs) are more likely to occur in years

when most other asset prices are low—such as during recessions. In the market,

losses in such years get more weight than those that might occur when other asset

prices are high, so lenders require additional compensation for taking on those

risks. The budget measure of cost does not recognize any compensation to

taxpayers for taking on those risks.4 As a consequence, the cost of credit programs

shown in the federal budget is understated relative to the burden that their

activities impose on taxpayers.5

The Subsidy Cost of FHA Insurance Based on

Market Prices

When available, market prices can provide a good indication of the economic cost

of government credit programs. In the case of FHA’s basic home mortgage

insurance, prices are available because private insurers provide comparable

coverage and quote their prices for such insurance publicly. If the market for

private mortgage insurance is sufficiently competitive, the quoted price will

approximate the minimum cost of providing that insurance for an efficient

provider. In that case, the difference between the premium charged by FHA and

that charged by private insurers would provide a measure of the subsidy cost of

FHA insurance.

In fact, the market for private mortgage insurance is by all indications highly

competitive. Eight insurers are currently providing coverage in the United States.

In addition, and perhaps more important, a large number of mortgage lenders

compete not by selling mortgage insurance directly but by providing equivalent

services through second mortgages and home-equity loans. Because first

mortgages for no more than 80 percent of the purchase price generally do not

require mortgage insurance, borrowers may take out a second mortgage that will

finance the remaining 20 percent and that will cover the risk of default, thereby

providing the insurance.

Private mortgage insurance is usually limited to covering 35 percent or 40 percent

of the unpaid mortgage balance, whereas FHA coverage is for nearly 100 percent

of the mortgage amount. However, for the lender, that difference is not significant

because the collateral value of the house provides a buffer to actual losses from

defaults. Consequently, unless the market price of the house falls to a level below

the mortgage insurance coverage, the lender will be protected from loss by the

proceeds from the sale of the foreclosed property. The very low loss experience of

4. See the statement of Douglas Holtz-Eakin, Director, Congressional Budget Office, The Economic

Costs of Long-Term Federal Obligations, before the House Committee on the Budget (July 24,

2003), available at www.cbo.gov.

5. Congressional Budget Office, Estimating the Value of Subsidies for Federal Loans and Loan

Guarantees (August 2004), available at www.cbo.gov.
6

the government-sponsored enterprises, which hold large portfolios of mortgages

with fractional private mortgage insurance coverage, illustrates the protection

provided by the collateral value of the house. To the extent that coverage by

private mortgage insurance is less comprehensive than that offered by FHA, the

premiums charged by private insurers will provide a low estimate of the cost of

FHA guarantees.

Premium rates for private mortgage insurance are quoted as a fixed annual

percentage of the amount of the loan and vary with the borrower’s down payment

and credit rating, as commonly measured by Fair Isaac & Co. (thus, the

borrower’s FICO score).6 Other variables, including what the term of the loan is

and whether the interest rate is fixed or adjustable, also affect the premium for

private mortgage insurance.

For CBO’s analysis, the comparison of premiums is for 30-year fixed-rate

amortizing mortgages for owner-occupied houses with loan-to-value ratios above

0.95––FHA’s standard product. FHA borrowers, on average, make down

payments of less than 5 percent.7 (Premiums for private insurance do not vary

among mortgages with loan-to-value ratios of 0.95 to 1.0.)

FHA fees are the same for all qualified borrowers: 1.5 percent of the loan amount

at origination (this fee can be financed in the mortgage) and an annual fee,

including one for the first year, of 0.5 percent of the unpaid balance. To facilitate

a comparison of private and FHA premiums, CBO converted FHA’s up-front fee

(using a 6 percent interest rate) to a fixed annual rate paid over eight years. Stated

as an annual fixed rate, FHA’s fees total 0.73 percent of the unpaid balance, or 73

basis points.8

For borrowers who have FICO scores of 620 and above, currently quoted private

insurance premiums for 40 percent coverage of 30-year fixed-rate mortgages of

owner-occupied single-family homes are 1.09 percent, or 109 basis points, per

year (see Table 1). Lower FICO scores require a higher premium.9

6. Fair Isaac is a private company that developed the system now widely used by lenders to assess the

credit quality of borrowers. For details, see www.FICO.com.

7. In 2005, loan-to-value ratios for FHA-insured mortgages ranged from less than 0.75 to more than

1.0, with 81 percent above 0.95. The median for values below 0.95 fell between that value and

0.80. See Federal Housing Administration, Actuarial Review of the Mutual Mortgage Insurance

Fund FY 2005, “Characteristics of the FY 2005 Book of Business” (November 2, 2005), available

at www.hud.gov/offices/hsg/comp/rpts/actr/2005sec4.pdf.

8. A basis point is one-hundredth of a percentage point.

9. When this report was prepared, the quoted national premiums for private mortgage insurance were

the same on various major firms’ Web sites.
7

Table 1.

Private and FHA Insurance Premiums for 30-Year FixedRate Amortizing Mortgages for Owner-Occupied SingleFamily Homes

(Basis points)

FICO Scorea

Premium for

Private

Insuranceb FHA Premiumc

Estimated

Percentage of FHA

Loans

620 and Higher 109 73 63

600 to 619 210 73 16d

575 to 599 287 73 12d

Lower Than 575 467 73 9

Weighted Average 179e 73 100

Source: Congressional Budget Office.

Note: A basis point is one-hundredth of a percentage point.

a. FICO scores are credit quality measures for borrowers calculated by Fair Isaac & Co.

b. Under an assumption that the loan-to-value ratio is 0.95 or higher and that FICO scores of 620 and

higher are accompanied by a rating of A and scores of 619 and lower, a rating of A-.

c. FHA charges fees of 1.5 percent of the loan amount at origination and 0.5 percent of the unpaid

balance per year. CBO has assumed that the average life of the mortgages and of the annual fee is

eight years. Discounted at 6 percent, the FHA premium is the equivalent of an annual fee of 0.73

percent, or 73 basis points.

d. FHA reports that the distribution of its home buyers for 2004 and 2005 by FICO score was as

follows: 620 and higher, 63 percent; 560 to 619, 28 percent; and less than 560, 9 percent. To allocate

the middle group to the two subgroups distinguished by private insurers for pricing, CBO has

assumed that 16 percent had FICO scores of 600 to 619 and that 12 percent had scores of 575 to

599.

e. The weighted average annual premium that FHA borrowers would pay in the private mortgage

insurance market.

According to FHA, in 2004 and 2005, 63 percent of its insured borrowers had

FICO scores above 620, and 9 percent had scores less than 560.10 CBO distributed

the remaining borrowers (those with intermediate credit quality) into two standard

categories recognized by private insurers. Using those assumptions, CBO

estimates that the weighted average of insurance premiums that private insurers

would charge FHA borrowers would be 179 basis points. That charge compares

with FHA’s premium of 73 basis points.

However, testimony by industry experts and the relative success of private

mortgage insurance suggest the possibility that private insurers offer superior

service and thus incur greater costs than FHA. For example, private insurers

10. Although FHA collects the FICO scores of borrowers, it is not required to use that proprietary

system to qualify borrowers.
8

appear to provide more convenient, timely, and responsive service. They also

actively market their products to lenders.

To adjust for that possibility, CBO estimates—on the basis of reported expense

ratios of a sample of private mortgage insurers—that the cost to the government

of FHA insurance is 50 basis points per year less than the total cost of private

insurance. With that adjustment, FHA is offering insurance that costs 129 basis

points but is charging purchasers only 73 basis points for it. Thus, FHA’s subsidy

cost for the MMI program is 56 basis points per year, equivalent to about 3.5

percent of the amount of the insured mortgages, CBO estimates.11 Because that

adjustment is uncertain, CBO has also calculated FHA’s subsidy rate under the

alternative assumptions that its annual net cost is 36 and 76 basis points less than

the cost of private insurance. With those adjustments, the subsidy costs translate

to between 2 percent and 5 percent of the amount of the insured mortgages. If

FHA insures $60 billion in new single-family mortgages each year, a subsidy rate

of 3.5 percent would mean that the cost of the program is about $2 billion

annually. That amount is the cost that U.S. taxpayers incur, mostly in the form of

bearing risk, to maintain the program’s activities.

Thus, in the case of FHA’s basic insurance of fixed-rate mortgages in the Mutual

Mortgage Insurance program, a comprehensive, market-based measure shows a

subsidy cost, whereas the estimates currently used in the budget show a gain. That

is, under the budgetary accounting rules mandated by FCRA, the MMI program

(its administrative costs excluded) appears to make money for the government.

For fiscal year 2007, for example, the Administration estimates that each $100 of

insurance sold will produce estimated net income to the government of 37 cents.

Administrative costs would add about 70 cents to that figure, resulting in a net

cost of about 33 cents per $100 of insurance, which is still far below the costs

indicated by market prices.12

Proposed Changes in Policy

The declining market share of FHA has prompted calls for restructuring the MMI

program. One proposal now under consideration by the Congress (H.R. 5121)

would give FHA the authority to be more like a commercial mortgage insurer in

operating the single-family mortgage program. That legislation would authorize

the agency to insure larger mortgages for terms of up to 40 years and would

abolish the requirement for borrowers to make a down payment to qualify for

11 . The private insurance premium (179 basis points) minus an adjustment for a difference in operating

costs (50 basis points) minus FHA’s fees (73 basis points). The annual subsidy of 56 basis points is

capitalized at 6 percent interest over eight years to obtain the up-front cost at origination of 3.5

percent.

12. That estimate of FHA’s annual administrative costs is obtained by expressing them as a percentage

of the total amount of outstanding insurance, or 0.10 percent (10 basis points) per year and

assuming that those costs are incurred for eight years on average. Using rates on Treasury securities

to discount that annual cost for eight years produces a net present value of about 70 basis points.
9

FHA insurance. It would also have FHA adopt a risk-based premium schedule so

that higher-risk borrowers would pay higher insurance premiums. In addition, the

bill would remove the current cap on the number of home-equity conversion

mortgages, a form of reverse mortgage provided to homeowners who are age 62

or older. The proposal would also widen the range of purposes for which such

mortgages could be used and potentially increase the demand for them.13

FHA has indicated that if it is granted authority to charge risk-adjusted premiums,

it would probably cut fees to the lowest-risk borrowers to an annual rate of 50

basis points per year and increase the rates to the highest-risk borrowers to an upfront fee of 3.0 percent and an annual fee of 0.75 percent, or the equivalent of 121

basis points per year for eight years.14 A fee of 50 basis points for low-risk

borrowers would be competitive with that offered by private insurers, who quote a

rate of 60 basis points per year for a borrower with a FICO score of 620 or higher

who is making a 10 percent down payment. However, a premium of 121 basis

points for high-risk borrowers would continue to provide a substantial subsidy to

them. For example, the private insurance rate for a borrower with a FICO score of

600 who is making a down payment of less than 5 percent is 210 basis points.

The proposal to make FHA more like a commercial insurer is not the only one

under consideration. Others include increasing the premium in the basic singlefamily mortgage insurance program to the maximum authorized levels of 2.25

percent up front and 0.55 percent annually; expanding the range of mortgages

eligible for insurance; adopting risk-based pricing; and using more-targeted

policies to assist low-income first-time homebuyers.15

Each of those proposals has advantages and disadvantages. However, an

important feature of current and proposed federal policy has been obscured by the

budget costs estimated under the FCRA accounting rules: insurance provided

under the MMI program by FHA, when evaluated at market prices, is subsidized

by the government. It is a use of taxpayer resources, and many of the alternatives

under consideration for expanding it entail higher costs to taxpayers.

13. For details and the estimated budgetary effects, see the Congressional Budget Office’s cost estimate

for H.R. 5121, the Expanding American Homeownership Act of 2006, June 14, 2006. The bill was

ordered reported by the House Committee on Financial Services on May 23, 2006.

14 . Statement of Brian D. Montgomery, Assistant Secretary for Housing-Federal Housing

Commissioner, Department of Housing and Urban Development, before the Subcommittee on

Housing and Community Opportunity, House Committee on Financial Services (April 5, 2006).

15. H.R. 1999 and S. 771, for example, would expand the use of vouchers for down payment

assistance.
10

Implications of Cost Measures for Alternative Policies

One implication of a comprehensive, market-based measure of costs is that the

current policy does not reduce the fiscal burden on taxpayers, as suggested by the

current entries in the budget. The Federal Housing Administration’s Mutual

Mortgage Insurance program costs taxpayers the equivalent of $2 billion

annually.

A second implication is that expanding the current program by enlarging the type,

size, and volume of mortgages eligible for insurance would increase total costs.

Increasing premiums to high-risk borrowers would limit the increase in costs, but

a premium of 121 basis points would cover only a share of the cost of insurance

for FHA’s high-risk borrowers. Total costs to taxpayers would increase under

current proposals that expand FHA’s program and therefore increase risk.

The FCRA subsidy estimates understate the cost of FHA guarantees relative to

that of other federal spending programs. Thus, a third implication is that the

current budgetary treatment results in a bias in favor of federal credit programs

and against other programs. For example, a proposal to spend $2 billion per year

for vouchers to permit high-risk first-time home buyers to purchase private

mortgage insurance would have a budget cost of $10 billion over a five-year

period, whereas the fiscally equivalent alternative of operating the MMI program

under current policy would be shown in the budget as having net savings of $1.8

billion for that same period.16

16. Direct assistance to qualified borrowers for down payments, closing costs, and rehabilitation is

currently provided through the American Dream Down Payment Initiative. The American Dream

Act authorized spending of $200 million annually for 2004 to 2007, and the program has received

appropriations of $167 million for the first three of those four years. Mortgage service assistance is

available from the Department of Housing and Urban Development’s Housing Choice/Housing

Certificate Fund.