Working Paper Series

Congressional Budget Office

Washington, D.C.

An Evaluation of Large-Scale Mortgage Refinancing Programs

Mitchell Remy

Financial Analysis Division

Congressional Budget Office

(Mitchell.Remy@cbo.gov)

Deborah Lucas

Sloan School of Management

Massachusetts Institute of Technology

(dlucas@mit.edu)

Damien Moore

Financial Analysis Division

Congressional Budget Office

(Damien.Moore@cbo.gov)

September 2011

Working Paper 2011-4

To enhance the transparency of CBO’s work and to encourage external review of it, CBO’s working 

paper series includes both papers that provide technical descriptions of official CBO analyses and papers 

that represent original, independent research by CBO analysts. Working papers are not subject to CBO’s 

regular review and editing process. Papers in this series are available at www.cbo.gov/publications (select 

Working Papers).

This paper is preliminary and is circulated to stimulate discussion and critical comment. The analytic 

approaches and conclusions in this paper are the authors’ and should not be interpreted as CBO’s.

We thank Mark Hadley, David Torregrosa, Aurora Swanson, Chad Chirico, Peter Fontaine, Mark Lasky, 

Ben Page, and Wendy Edelberg for helpful comments and suggestions. We also thank Francesca Castelli 

for modeling assistance and Rebecca Rockey for research support.
An Evaluation of Large-Scale Mortgage 

Refinancing Programs

Abstract

We analyze a stylized large-scale mortgage refinancing program that would relax current income and 

loan-to-value restrictions for borrowers who wish to refinance and whose mortgages are currently insured 

by Fannie Mae, Freddie Mac, or the Federal Housing Administration. The analysis relies on an estimate 

of the volume of incremental refinancing that would occur and an estimate of how future default and 

prepayment behavior would be affected by such refinancing. Relative to the status quo, the specific 

program analyzed here is estimated to cause an additional 2.9 million mortgages to be refinanced, 

resulting in 111,000 fewer defaults on those loans and estimated savings for the GSEs and FHA of 

$3.9 billion on their credit guarantee exposure, measured on a fair-value basis. Offsetting those savings, 

federal investors in MBSs, including the Federal Reserve, the GSEs, and the Treasury, would experience 

an estimated fair-value loss of $4.5 billion. Therefore, on a fair-value basis, the specific program analyzed 

here would have an estimated cost to the federal government of $0.6 billion. (The proposal analyzed here 

is a stylized one, and the estimated costs are not reported entirely according to the rules governing federal 

budget accounting; the figures in this paper do not represent a CBO cost estimate of a legislative 

proposal.) Because the estimated gains and losses are small relative to the size of the housing market, the 

mortgage market, and the overall economy, the effects on those markets and the economy would be small

as well. We also discuss the impact of this program on various stakeholders, including homeowners, nonfederal mortgage investors, mortgage lenders, mortgage service providers, private mortgage insurers, and 

subordinated mortgage holders. For example, non-federal investors would experience an estimated fairvalue loss of $13 to $15 billion; most of that wealth would be transferred to borrowers.
Table of Contents

Introduction...................................................................................................................................................1

Background...................................................................................................................................................4

Current Constraints on Mortgage Refinancing .........................................................................................5

Existing Programs and Proposals..............................................................................................................9

Design Considerations for a Large-Scale Refinancing Program ................................................................12

Estimating Participation in a Large-Scale Refinancing Program ...............................................................13

A Stylized Program.................................................................................................................................13

Characterizing the Affected Borrower Population..................................................................................14

Calculating Incremental Refinancing......................................................................................................15

Impediments to Program Participation ...................................................................................................18

Costs and Benefits of the Program..............................................................................................................19

Benefits to Homeowners and the Economy............................................................................................19

Costs and Benefits to Federal Entities ....................................................................................................20

Calculating Guarantee Savings...........................................................................................................21

Calculating Portfolio Losses...............................................................................................................22

Costs and Benefits to Non-Federal Stakeholders....................................................................................23

Non-Federal Investors.........................................................................................................................23

Lenders and Other Service Providers..................................................................................................23

Private Mortgage Insurers and Subordinate Mortgage Investors........................................................24

Macroeconomic Benefits........................................................................................................................24

Sensitivity of Results to Alternative Policy Choices..................................................................................25

Discussion...................................................................................................................................................26

Appendix: Fair Value and Alternative Budgetary Treatments of Credit Programs....................................27
1

Introduction

Although the broader U.S. economy appears to be gradually recovering, the housing market remains 

weak. In addition to the significant number of mortgages in some stage of delinquency or default, many 

homeowners are unable to refinance to take advantage of historically low mortgage rates. The unusually 

low level of refinancing activity has prompted a number of proposals for federal programs that would 

provide refinancing opportunities to more mortgage borrowers. Such a program would allow participants 

to lower their monthly mortgage payments, freeing up household income for non-housing expenditures. It 

could also help some portion of struggling borrowers avoid a future default.

The ongoing housing crisis and the slow recovery from the recent recession have locked many borrowers 

out of the refinancing market. Two main factors drive that phenomenon:

• Weakened household balance sheets, reduced income and widespread unemployment have left 

many borrowers unable to qualify for a refinancing because of restrictions based on affordability

tests. For some the constraint is a too high loan-to-value (LTV) ratio—the amount of mortgage debt 

divided by the assessed value of the home.1

• Lenders and mortgage guarantors, including the government-sponsored enterprises (GSEs) Fannie 

Mae and Freddie Mac and the Federal Housing Administration (FHA), have instituted more 

stringent underwriting requirements, leaving many borrowers unable to qualify for a new loan even 

if they have remained current on their existing mortgages. 

Policymakers have responded to these constraints by introducing new refinance programs, such as the 

GSEs' Home Affordable Refinance Program, HARP, and programs offered by FHA. Although those 

programs have helped some homeowners, program features and eligibility criteria exclude a significant 

number of borrowers who would benefit from a refinancing. For example, in 2010 Fannie Mae and 

Freddie Mac refinanced, through HARP, nearly 30,000 loans with a current LTV between 105 percent 

and 125 percent (the program maximum). This compares to the more than $762.5 billion of mortgages (or 

approximately 5 million loans assuming an average balance of $150,000) in the GSEs’ portfolio that had 

a current LTV greater than 100 percent at the end of the fourth quarter of 2010.2

Existing federal mortgage refinancing programs and most proposals for new federal programs restrict 

eligibility to borrowers with mortgages insured by the GSEs or other federal agencies including the FHA, 

which collectively guarantee more than 56 percent of mortgages outstanding. Federal taxpayers are 

already obligated to bear the losses from default on those mortgages, so allowing those borrowers to 

refinance their loans would not increase the taxpayers’ exposure to default loss. In fact, taxpayers would 

A refinancing program

that relaxed LTV limits and income tests, waived appraisal requirements, or allowed delinquent 

borrowers to participate in the program, could make refinancing at current market rates feasible or less 

expensive for many borrowers.

 1 In this paper, LTV calculation is based on the first mortgage balance. The combination of first mortgage and any 

subordinate mortgages is referred to as combined loan-to-value (CLTV). 2 HARP data are from Federal Housing Finance Agency, Foreclosure Prevention & Refinance Report, Fourth 

Quarter 2010. Current LTV data are from the Q4 2010 credit supplements from Fannie Mae and Freddie Mac.
2

benefit from lower losses on such guarantees, because the reduced financial burden from a lower 

mortgage payment would reduce the likelihood of default. 

Although such a program would benefit borrowers and would lower federal guarantee costs, it would be 

costly to mortgage investors, who would experience losses on mortgages that are prepaid more rapidly 

than in the absence of the program. Some of those investment losses would be borne by the federal 

government, which, through the Federal Reserve, the GSE portfolios, and the Treasury, has substantial 

holdings of mortgage-backed securities (MBSs).

In this paper, we analyze the potential impact of a stylized program that would increase the availability of 

refinancing and slightly lower its cost. Specifically, the program would eliminate current loan-to-value 

and borrower income restrictions on refinancing existing loans guaranteed by Fannie Mae, Freddie Mac, 

or FHA. The new mortgages would have a maturity of 30 years and a fixed interest rate set at the 

prevailing market rate. The new guarantee fee would be limited to the fee on the existing loan. Eligibility 

would be limited to borrowers who are current on their existing mortgages. The program would be 

available for one year.

We use a probabilistic model of borrower behavior that CBO developed, estimated from the historic 

performance of GSE and FHA mortgages, in which borrower default and prepayment rates respond to 

changes in interest rates and home prices. Using the current population of loans guaranteed by the GSEs 

and FHA, the model allows us to assess the incremental refinancing volume expected under the stylized 

program. Those estimates of incremental refinancing activity serve as the basis to assess: 

• Borrower Benefits: Borrowers who refinance experience the benefit of lower mortgage costs and 

less risk of defaulting in the future. In addition, both borrowers and their local communities 

benefit from avoiding the economic and social costs of the defaults and foreclosures that would 

otherwise occur. 

• Guarantee Savings: Lower monthly payments for borrowers who refinance through the program 

reduce the probability of future defaults on the refinanced loans. As guarantors of those loans, the 

GSEs and FHA benefit in the form of lower expected costs.

• Investor Losses: Investors in the MBSs backed by the existing loans suffer a loss in the value of 

their investments, particularly for securities that are trading at prices that reflect the market’s 

expectation that refinancing is unlikely. Those investors include both federal entities (the Federal 

Reserve, U.S. Treasury, and the GSEs) and non-federal entities (U.S. financial institutions, 

pension funds, foreign governments, and other private investors). Losses experienced by federal 

entities represent a cost to taxpayers.

• Other Stakeholders: The program would affect many additional stakeholders in the mortgage 

finance industry, including lenders (as loan originators), servicers, mortgage insurers, and thirdparty service providers; some would benefit but others would lose.

• Macroeconomic Benefits: Lower monthly mortgage payments for borrowers would produce a 

short-run stimulus because those borrowers would tend to increase their spending. (The stimulus 

effect would be slightly offset by the reduction in spending arising from capital losses to private 

investors.) Although not quantified in our analysis, the stimulus is likely to be small as a 

percentage of GDP, but large relative to the net federal cost of the program. The effects on the

housing and broader markets from increased spending and averted defaults are likely to be small
3

because the gains and losses to borrowers and investors are likely to be small relative to the sizes 

of those markets.

Costs reported in this paper are calculated on a fair-value basis. Although that approach is consistent with 

CBO’s budgetary treatment of the GSEs, it differs from the budgetary treatment of both the Federal 

Reserve, reflected in the budget on a cash basis, and the MBS purchases of the U.S. Treasury, presented 

on a Federal Credit Reform Act of 1990, or FCRA (Public Law 101-508), basis. With those differences in 

mind, reported costs in this paper are meant to provide an internally consistent measure of cost but not an 

estimate of the federal budgetary cost of a large-scale refinancing program. The proposal analyzed here is 

a stylized one and the estimated costs are not reported entirely according to the rules governing federal 

budget accounting. The figures in this paper do not represent a CBO cost estimate of a legislative 

proposal. 

Under our base case assumptions, the stylized program is estimated to cause an additional 2.9 million 

mortgages to be refinanced, resulting in 111,000 fewer defaults on those loans and resulting in savings for 

the GSEs and FHA of $3.9 billion on their credit guarantee exposure, measured on a fair-value basis.

3

Non-federal investors hold approximately 65 percent of the outstanding MBSs included in the analysis. In 

addition to holding a larger share of the market than federal investors, those non-federal investors also 

hold a greater proportion of older, higher-coupon securities; the Federal Reserve and the Treasury 

purchased a large share of recently issued, lower-coupon MBSs as a part of their recent market 

interventions. As a result, non-federal investors are expected to experience a fair-value loss of $13 to 

$15 billion—about three times the size of the loss to federal investors.

Offsetting those savings, federal investors in MBSs, including the Federal Reserve, the GSEs, and the 

Treasury, would experience a loss of $4.5 billion (also on a fair-value basis). The net federal cost would 

be an estimated $0.6 billion. From the borrowers’ perspective, savings from lower mortgage payments is 

projected to total $7.4 billion in the first year of the program; the associated effect on consumption would 

decline significantly over time as borrowers pay off those loans.

In practice, the effects of such a program would depend significantly on several factors, including the 

design of the program (for instance, the fee structure and the eligibility criterion), the willingness of 

mortgage industry firms (lenders, mortgage insurers, and other ancillary service providers) to participate 

in the program, borrower acceptance, and the future movements of interest rates, home prices, and other 

economic variables.

Some analysts and advocates have called for large-scale mortgage refinancing programs that would 

include principal forgiveness by lenders or guarantors on mortgages where the loan balance significantly 

exceeds the value of the home, and others have called for refinancing programs that would offer 

borrowers new mortgage rates below current market rates. Such policies could have much larger effects

on the housing market and the economy, but probably only if they also entailed significantly higher costs 

to the federal government. Policies of that sort are outside the scope of this paper’s analysis.

 3 The savings are calculated on a fair-value basis, which is an estimate of the market value of the averted defaults.
4

Background

The terms of most mortgage loans in the United States permit the borrower to refinance without penalty 

or restriction. That is the case for loans guaranteed by Fannie Mae, Freddie Mac, or FHA. Because of 

those terms, investors expect that many borrowers with a financial incentive to refinance will do so. Apart 

from lowering their interest rate, borrowers may have an incentive to refinance for several reasons: to

reduce the monthly payment; to obtain a more desirable amortization schedule (for example, moving from 

an interest-only loan to one with monthly principal and interest payments to eliminate a potential balloon 

payment, or changing the term to maturity on the mortgage); to reduce risk by moving from a floatingrate loan to a fixed-rate loan; or to extract accumulated equity as a means for increasing funds available 

for spending (also known as a cash-out refinancing).

Those benefits are weighed against the financial and non-financial costs associated with obtaining a new 

loan, including appraisal costs, origination fees, title fees, settlement fees, taxes, and the time and effort 

necessary to obtain the refinanced loan. The ultimate decision to refinance incorporates not only the 

borrowers’ assessment of the direct costs and benefits of the transaction but also includes additional 

considerations, including the remaining term of the mortgage and how long they expect to remain in the 

home, their current credit profile, their expectation of future interest rates, and other factors.4 Finally, 

borrowers will weigh the decision to refinance against the other option inherent in their mortgage—the 

ability to default. Borrowers with significant negative equity or credit constraints may find that option 

particularly valuable and thus an extremely important consideration.

5

The option to refinance granted to mortgage borrowers is not free to them. Investors in mortgages and 

MBSs are exposed to prepayment risk and will adjust the price they are willing to pay for those assets 

based on the perceived level of exposure. That compensation for prepayment risk is passed through to 

mortgage borrowers in the form of higher initial interest rates.6

In recent years, refinancing loans have represented a significant portion of total loan originations, 

particularly in periods of falling interest rates. Chart 1 provides a clear picture of that relationship during 

recent “refinancing waves” in 1992–1993, 1998, and 2001–2003. In each case, mortgage rates dropped 

more than 2 percentage points, sparking an increase in borrowers looking to lock in those lower rates.

Since the early 1990s, several changes in the mortgage market have increased borrowers’ likelihood to 

refinance. Some of those changes include the advent of automated underwriting systems (most notably 

Fannie Mae’s Desktop Underwriter and Freddie Mac’s Loan Prospector), the widespread use of credit 

scores and automated property-valuation models, and the development of streamlined refinancing

 4 Many aspects of a borrower’s decision to refinance fit within a traditional option pricing framework. For a 

description of that approach, see Paul Bennett, Richard Peach and Stavros Peristiani, “Structural Change in the 

Mortgage Market and the Propensity to Refinance,” Journal of Money, Credit and Banking, 33: 955–975, 2001. 5 For a discussion of the relationship between default and prepayment behavior in mortgage valuation, see 

Yongheng Deng, John M. Quigley and Robert Van Order. “Mortgage Terminations, Heterogeneity and the Exercise 

of Mortgage Options,” Econometrica, vol. 68, no. 2; March 2000. 6 For discussion of prepayment risk and its effect on MBS investors, see “The Handbook of Mortgage-Backed 

Securities,” Frank Fabozzi, ed., 2001.
5

products by the GSEs, FHA, and many financial institutions which have made the refinancing process 

both less costly and more efficient for both borrowers and lenders.7

Chart 1. Single Family Annual Mortgage Originations and 30-year Fixed-Rate Mortgage Rates

Source: Origination data from the Mortgage Bankers Association. Mortgage debt outstanding data from the Federal Reserve Board. 30-year 

mortgage rate from Freddie Mac.

Current Constraints on Mortgage Refinancing

Despite rates dropping more than 1.5 percentage points since 2007, refinancing volumes have not seen a 

spike similar to previous refinancing waves. Some explanations for the lack of refinancing activity are 

largely unconnected to the recent financial crisis. First, a significant portion of current mortgages were 

originated in the low-rate environment that has existed since 2003. According to data provided by 

Bloomberg on 30-year MBSs guaranteed by Fannie Mae, Freddie Mac, and FHA, approximately 

46 percent of loans have an interest rate lower than 5.5 percent, and 67 percent have an interest rate lower 

than 6 percent.

8 Under recent interest rate conditions, a majority of borrowers might not receive the 1 to 

2 percentage point improvement in interest rate generally cited as the trigger for refinancing for rate 

reduction.9

 7 Streamlined refinancing products allow borrowers to refinance, often with the same lender, without undertaking 

many of the steps of a traditional refinancing, including income and asset documentation, employment verification 

and property appraisal.

Second, because rates have remained low for an extended period of time, many borrowers 

8 Loans guaranteed by FHA are securitized in Ginnie Mae MBSs, which also contain loans guaranteed by the U.S. 

Department of Veterans Affairs’ (VA), the U.S. Department of Housing and Urban Development’s Office of Public 

and Indian Housing, and the U.S. Department of Agriculture’s Rural Development programs.

9 See Sumit Agarwal, John C. Driscoll and David Laibson, “Optimal Mortgage Refinancing: A Closed Form 

Solution,” October 2007, for fuller discussion of refinancing economics.

0

2

4

6

8

10

12

0%

5%

10%

15%

20%

25%

30%

35%

40%

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Mortgage Rate (%)

Originations as a % of Mortgage Debt Outstanding

Refinance Originations 30yr Mortgage Rate
6

inclined to refinance for rate reduction have already done so. Refinance volumes have exceeded 

$1 trillion in each year after 2003, with the exception of the depths of the financial crisis in 2008.

It is widely acknowledged that impediments to refinancing high-interest-rate loans have increased in the 

wake of the financial crisis. In addition to the limited options facing borrowers—resulting from negative 

equity created by home price declines, reduced income or unemployment, and the continued high levels 

of consumer debt accumulated over the past decade—many lenders and private mortgage insurers have 

tightened their underwriting standards. Lenders have been tightening their underwriting standards for both 

prime and non-traditional mortgages during the past few years (see Chart 2). As a result, underwriting 

standards are significantly more restrictive than they were at the start of the financial crisis. Examples 

include the drastic curtailment of interest-only and negative amortizing loan guarantees issued by the 

GSEs since 2008 and the institution of minimum credit scores, LTV ratios, and other risk management 

policies by FHA.10

Chart 2. Net Percentage of Loan Officers (Domestic Respondents) Tightening Standards for Residential 

Mortgage Loans

Another sign of tightening is that private lenders, the GSEs and the FHA now charge 

higher fees or rates than before the crisis on mortgages made to less creditworthy borrowers or with LTV 

ratios at origination that exceed 80 percent.

11

Source: Federal Reserve Board Senior Loan Officer Opinion Survey on Bank Lending Practices, April 2011.

 10 See Fannie Mae 2011 First-Quarter Credit Supplement and FHA Mortgagee Letter 2010-29. 11 A value greater than zero means more respondents in the survey indicated that they have tightened lending 

standards than those that indicated standards have loosened or remained the same. The nontraditional category 

includes but is not limited to adjustable-rate mortgages with multiple payment options, interest-only mortgages, and 

Alt-A products such as mortgages with limited income verification and mortgages secured by non-owner-occupied 

properties.

-20

-10

0

10

20

30

40

50

60

70

80

90

100

Net %

Prime Nontraditional
7

A further indication of the continuing dislocation in the mortgage market is the distribution of new 

originations between the GSEs, FHA, and the private market. In the first half of 2011, the GSEs, FHA 

and VA averaged 95 percent of new originations, continuing the trend of the past few years, far above 

levels during the peak of the housing boom and far above the pre-boom average of approximately 50 to 

55 percent. The GSEs and FHA also continue to play an important role in the jumbo loan market 

(generally loans above $417,000).

12

Chart 3. Mortgage Originations by Source

Increases in federally backed market share in both the jumbo market 

and the non-jumbo market have come even as both the GSEs and FHA have instituted a number of

guarantee fee increases since the onset of the crisis. Charts 3 and 4 provide evidence of the prominence of 

the GSEs and FHA in recent years. Prospects for a rebound in the private market remain uncertain, with 

some analysts estimating that mortgage spreads would need to rise considerably for securitizations to 

become profitable again for non-federally guaranteed MBSs.

Source: Constructed from estimates by Inside Mortgage Finance.

 12 The expanded authority to guarantee jumbo mortgages is scheduled to expire on September 30, 2011, at which 

time the limit in high-cost areas will drop from $729,750 to $625,500.

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 H1

2011

% of Total Originations

FHA/VA GSE Other
8

Chart 4. Jumbo Originations

Source: Constructed from estimates by Inside Mortgage Finance

A measure of the difficulty borrowers are experiencing in refinancing their mortgages is the unusually 

high premium over the face (or par) value that investors are willing to pay for MBSs with high coupon 

rates. The availability of the option to prepay the mortgage usually prevents the price of MBSs from 

rising too much above par value. In general, a coupon-paying bond, including a mortgage-backed 

security, will increase in value when interest rates fall. For MBSs, however, large increases above par 

value are uncommon because the decline in interest rates tends to speed up the rate of prepayment on the 

underlying mortgages and, hence, MBS investors do not expect to receive an above-market coupon for 

very long. The current high pricing suggests that investors expect impediments to refinancing to prevail 

considerably longer than usual. Chart 5, based on Fannie Mae 30-year MBSs that have coupons that are 

approximately 1.5 percent above the prevailing par coupon rate, shows that investors have increased the 

price for those securities since 2009. Although many factors affect pricing for MBSs, a strong case can be 

made for lower prepayment expectations as an important component in the price premium investors are 

currently willing to pay for those securities.

$0.0

$100.0

$200.0

$300.0

$400.0

$500.0

$600.0

$700.0

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

$s billion

Agency Jumbo Non-Agency Jumbo
9

Chart 5. Weekly Pricing for Premium Fannie Mae 30-year Fixed-Rate MBSs

Source: Bloomberg data for Fannie Mae 30-year MBSs.

Existing Programs and Proposals

To address the lack of opportunities for borrowers with above-market mortgages to refinance, the 

Administration introduced the HARP, launched in tandem with the Home Affordable Modification 

Program (HAMP) in 2009. Since inception through the first quarter of 2011, the GSEs have refinanced 

nearly 750,000 borrowers through HARP. Approximately 700,000 of those borrowers had a current LTV 

of less than 105 percent, and the remaining (approximately 50,000) had LTVs between 105 percent and 

125 percent.

HARP, which targets loans owned or guaranteed by the GSEs, provides flexibility that does not exist in 

the GSEs’ standard refinancing programs. In particular, HARP allows borrowers with current LTVs up to 

125 percent to refinance without increasing the current level of private mortgage insurance (PMI) 

attached to their loan. Although that feature reduces the cost of the refinanced loan to the borrower, other 

program parameters are less flexible than those in some proposals for a more comprehensive large-scale 

refinancing program. HARP requires borrowers to demonstrate that they have sufficient income to make 

the new payments, even if they are current on their more costly existing mortgage. The program limits 

current LTV to 125 percent, excluding many homeowners with the most severe negative equity. It also

requires borrowers to be current on their existing loan, and not to have been more than 30 days past due 

on a payment over the past year. Finally, the program extends only to existing GSE borrowers.

FHA offers two different programs designed to increase access to refinancing. The streamlined 

refinancing program targets existing FHA loans and provides for both reduced documentation and lower 

 102

 103

 104

 105

 106

 107

 108

Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Jan-10 Jan-11

Price for approx. 150 bps above par Average price for approx. 150 bps above par (2000 to 2006)

Note: Par = 100
10

costs. To qualify for a streamlined refinancing, borrowers must be both current on their existing loan, pass 

traditional underwriting criteria for sustainability, and have a maximum combined LTV of less than 

125 percent.

13 The much smaller Short Refinance program allows for the refinancing of non-FHA loans 

into a loan guaranteed by FHA. The program’s main benefit to borrowers comes from the requirement 

that the loan must be written down to a level necessary to create a new loan with an LTV less than 

97.75 percent. Although that lower loan balance would most likely reduce monthly mortgage payments, 

borrowers must still qualify for the loan based on a standard FHA underwriting. FHA completed nearly 

213,000 streamlined refinancing loans in fiscal year 2010 and is on pace to achieve the same volume in 

fiscal year 2011. As of April 2011, only 151 Short Refinance loans had been executed in fiscal year 2011 

(with none in fiscal year 2010).14

Policy makers, market participants, and academics have offered several proposals designed to address the 

limited success of HARP and the two FHA programs. The best known of those proposals are bills 

introduced in both houses of Congress15

 13 Includes subordinate financing. LTV is based on either a new appraisal or the original appraised amount.

and proposals put forth by R. Glenn Hubbard and Christopher 

Mayer, and by David Greenlaw. Although the details differ, each proposal aims to significantly boost

refinancing activity by relaxing eligibility rules, including accepting higher LTV mortgages and less 

financially secure borrowers. Some proposals also limit the fees that may be charged on the refinanced 

loan. Table 1 provides a brief summary of existing and proposed programs.

14 FHA Single-Family Outlook Report, April 2011 15 Housing Opportunity and Mortgage Equity Act of 2011 (H.R. 363, 112th Congress, 1st Session 2011) and the 

Helping Responsible Homeowners Act (S. 170, 112th Congress, 1st Session 2011)
11

Table 1. Existing and Proposed Refinancing Programs

Existing Programs Key Features and Restrictions

Home Affordable Refinance 

Program (HARP)

• Allows for refinancing of loans owned or guaranteed by Fannie Mae and 

Freddie Mac.

• Borrower required to pay designated Fannie Mae and Freddie Mac loan 

level price adjustments, which are fees based on assessed risk.

• Existing level of private mortgage insurance may be retained on new 

loan, even if current loan to value has increased.

Restrictions

• Borrower must be current on existing mortgage and must not have been 

more than 30 days late on mortgage payment during prior year.

• Existing loan must be less than 125 percent of current home value.

• Borrower must display ability to make new payment.

FHA Streamlined Refinance • Allows for refinancing of FHA loans.

• Provides for reduced documentation and underwriting required to be 

performed by the lender.

• Borrower upfront costs can be reduced in exchange for either a higher 

note rate or a larger mortgage principal balance.

Restrictions

• Borrower must be current on existing mortgage.

• Existing loan must be less than 125 percent of current home value.

• Borrower must display ability to make new payment.

FHA Short Refinance • Allows for refinancing of non-FHA loans.

• Holder of existing first mortgage must agree to write off at least 10

percent of unpaid principal balance of the mortgage, resulting in a new 

FHA loan of no more than 97.75 percent loan-to-value (and a combined 

loan-to-value of 115 percent if a subordinate mortgage exists).

Restrictions

• Borrower must qualify for the new loan under standard FHA 

underwriting requirements (including having a credit score equal to or 

greater than 500).

Proposed Programs

Housing Opportunity and 

Mortgage Equity Act

(H.R. 363)

• Allows for refinancing of loans owned or guaranteed by Fannie Mae and 

Freddie Mac.

• Both current and delinquent borrowers are eligible.

• Prohibits appraisal to establish current loan to value.

• Limits interest rate and fees borrower may be charged on new loan.

Helping Responsible 

Homeowners Act (S. 170)

• Allows for refinancing of loans owned or guaranteed by Fannie Mae and 

Freddie Mac.

• Borrower must be current on existing mortgage.

• Removes limit on current loan to value.

• Limits interest rate and fees (including loan level price adjustments and 

delivery fees) borrower may be charged on new loan.
12

Proposed Programs

Proposals by R. Glenn 

Hubbard and Christopher 

Mayer, and by David 

Greenlaw

• Allows for refinancing of mortgages owned or guaranteed by Fannie Mae, 

Freddie Mac, FHA, and VA.

• Describes a process that does not require new underwriting of borrower 

and proposes no limits on loan-to-value or borrower debt-to-income ratio 

(a measure of affordability of the loan).

• Encourages servicers and lenders to limit fees associated with new loans.

Fees are included in the principal balance of the new loan to reduce upfront 

costs to the borrower.

• Early proposal by Hubbard and Mayer suggested allowing all owneroccupied loans to be refinanced at 5.25 percent with Fannie Mae and 

Freddie Mac.16

Source: Public disclosures and program documentation.

Design Considerations for a Large-Scale Refinancing Program 

The scope and cost of any new large-scale mortgage refinancing program may vary considerably

depending on several key design choices. Those include the types of mortgages that qualify, the 

determinants of borrower eligibility, the amount of any subsidies (for instance, offering below-market 

interest rates), the size and structure of associated transactions costs, and the incentives for lender and 

servicer participation.

Loans that are eligible for refinancing could be limited to those already guaranteed by the GSEs. 

Alternatively, the program could also include mortgages guaranteed by federal agencies such as FHA, or 

non-federal or so-called private-label mortgages. Refinancing of loans guaranteed by both the GSEs and

federal agencies would reduce existing federal liabilities by reducing the probability of future defaults on 

those mortgages (and would also impose losses on the federal government by reducing the value of 

mortgage-backed securities, as discussed below). The expected savings would differ depending on 

mortgage and borrower characteristics. By contrast, extending the program to private-label mortgages and 

allowing those borrowers to refinance into loans with new federal guarantees could significantly increase 

federal costs by adding a significant new source of risk exposure. The higher costs could be partially 

offset by charging higher guarantee fees, but the fees would reduce the number of borrowers who could 

benefit from refinancing.

Some proposals allow borrowers who are delinquent on their existing mortgages to participate, whereas 

under other proposals borrowers must be current on their payments. Allowing delinquent borrowers to 

refinance at lower rates would make their mortgages more affordable and in some cases could avoid 

foreclosures. However, a subsequent default on a refinanced loan may entail additional costs if the value 

of the property decreases or if other costs increase as a result of granting the new loan. An additional issue 

is the extent to which delinquent borrowers with no intention of becoming current opt to refinance as a 

means of “resetting” their delinquency to delay the loss of their home.

The fees that the GSEs and FHA charge on the loans that they refinance could significantly affect 

program participation rates and federal cost. Charging higher fees would tend to reduce the federal cost of 

 16 R. Glenn Hubbard and Christopher Mayer, “First, Let's Stabilize Home Prices,” Wall Street Journal, October 2, 

2008
13

the program, but also would reduce the number of borrowers expected to participate (particularly if the 

fees take the form of significant upfront payments that require borrowers to come up with cash at the 

closing of the loan). Conversely, if the GSEs and FHA set fees at lower levels that would generate less 

revenue than is currently expected from those loans, it would increase the cost to the federal government 

and also tend to increase the program participation rates. 

The degree to which underwriting procedures (including verification of borrower income and assets) and 

the ancillary services and fees required for a traditional refinancing are either waived or subsidized for 

loans in the program could significantly affect participation rates. Making a loan through the program 

easier to close and less costly for the borrower will increase participation among borrowers who view the 

financial and non-financial cost of a new loan as an impediment. However, eliminating certain aspects of 

a traditional loan underwriting and closing (including title services) or requiring service providers to offer 

them at a reduced cost may yield a loan with less appeal to potential investors, and hence would result in 

somewhat higher interest rates on the new loans. It also may lower incentives for lenders and other 

service providers to participate in the program.

A final consideration is the degree to which the current LTV is utilized in program eligibility criteria.

Limiting the level of negative equity permitted on the refinancing may mitigate the severity of the loss 

should the borrower default on the new loan. Once again, however, that risk of loss is one that the 

guarantor already has and hopes to reduce through the lower probability of default created by the lowercost refinancing. A related question is whether the current LTV is even assessed, through an appraisal or 

an automated valuation process, during the refinancing process. Eliminating the appraisal may produce an 

additional cost saving for borrowers at the expense of not providing investors with an up-to-date 

assessment of the potential risk of default inherent in the new loans.

Estimating Participation in a Large-Scale Refinancing Program 

To quantify the potential effects of a large-scale refinancing program, we analyzed a stylized program that 

draws on the structure of current and proposed programs. The analysis relies on an estimate of the volume 

of incremental refinancing—those refinancings that would not have occurred absent the relaxed eligibility 

requirements and reduced costs provided under the program—and an estimate of how future default and 

prepayment behavior are affected by a mortgage being refinanced at a lower monthly payment (based on 

both a reduced interest rate and a potentially longer amortization term). The analysis is based on models 

developed by CBO to predict mortgage prepayments, defaults, and the severity of default as functions of 

borrower characteristics, loan terms, and economic conditions. The economic assumptions, particularly 

for interest rates and house prices, are consistent with CBO’s January 2011 baseline forecast.17

A Stylized Program

For the purposes of the analysis, we considered the following stylized program parameters:

• The program starts in the first quarter of 2012 and will be available for one year.

• Eligibility includes existing loans guaranteed by Fannie Mae, Freddie Mac, or FHA. 

 17 See Congressional Budget Office, Budget and Economic Outlook: Fiscal Years 2011 to 2021, January 2011. CBO 

subsequently updated its economic projections. See The Budget and Economic Outlook: An Update, August 2011.
14

• A borrower must be current on an existing mortgage and must not have been more than 30 days 

late on any mortgage payments during the prior year, but there are no limits on the borrower’s 

current income or on the loan-to-value ratio of the new loan.

• The GSEs and FHA will assess a guarantee fee equal to the fee charged initially on the existing 

loan. The fee will be incorporated into the interest rate on the new loan by the GSEs and charged 

as an annual premium by FHA. 

• The new loan has a fixed rate of interest, at the prevailing market rate, and a term of 30 years.

• Lenders and select third parties (for example, closing services and title search to ensure no new 

liens have been placed on the property) charge fees amounting to the lesser of 1 percent of 

principal or $1,000 to process the loan.

The program shares many of the features of existing proposals for a large-scale refinancing program.

Eliminating current LTV or borrower income limits and restricting the ability to charge fees on the 

refinanced loans are key elements driving participation and are primary points of departure from existing 

programs such as HARP and FHA’s Streamlined Refinance. Allowing FHA loans in addition to GSE 

loans is a significant difference between the stylized program considered here and the two bills before

Congress.

Characterizing the Affected Borrower Population

Summary data provided by Bloomberg on the dollar amounts, coupons, origination dates, and prices of 

30-year and 15-year MBSs guaranteed by Fannie Mae, Freddie Mac, and FHA (through Ginnie Mae 

securitizations) determine the potentially eligible population of existing mortgages.

18

To capture differences in the behavior, costs, and risks associated with different borrowers, but to keep 

the analysis relatively simple, we classify the population of borrowers who could refinance into 

representative groups based on the interest rate on their current mortgage, on whether the mortgage was 

originally a 30-year or 15-year fixed-rate mortgage, and on risk category. The risk categories reflect the 

characteristics that affect borrowers’ propensity to default on their mortgages, and are designated as high, 

medium, and low risk. Each group is further characterized by the following variables (Table 2 provides an 

overview of the loan groupings):

According to 

Bloomberg, those MBSs had outstanding balances totaling $4.3 trillion as of June 1, 2011. Of that total, 

Fannie Mae and Freddie Mac guarantee $3.5 trillion. (The estimates reported here are based on the 

Bloomberg sample; Fannie Mae and Freddie Mac guarantee an additional $1.5 trillion or so of mortgages 

that may have adjustable rates—ARMs—or other non-traditional terms, or that are held by the GSEs as 

whole loans rather than in an MBS. Some of those borrowers might also benefit from an easing of 

refinancing rules. We excluded ARM and non-traditional borrowers from the analysis because of the 

complexities associated with estimating the incentive to refinance into a fixed rate loan. In addition, we 

excluded whole loans held in the GSEs’ portfolios, because a growing percentage of those loans were 

recently modified or are currently non-performing.)

• Borrower FICO score19

 18 According to Ginnie Mae’s 2010 Annual Report, FHA loans represent approximately 80 percent of Ginnie Mae 

securities. The FHA volumes are based on the outstanding balances reported for Ginnie Mae securities, adjusted 

downward by 20 percent to exclude non-FHA loans. 19 Borrower credit scores were calculated using models developed by Fair Isaac Corporation (FICO).
15

• Current, or mark-to-market, loan-to-value (MTMLTV) ratio on existing mortgage

• Origination year of existing mortgage

• Interest rate on existing mortgage

• Imputed interest rate on new mortgage

In total, potential refinancers are classified into 108 distinct groups, representing the combination of 2 

maturities, 9 coupon rate pools, and 3 risk categories for the GSE population and for the FHA population. 

Total program costs are the sum of the estimated cost per dollar of loans outstanding multiplied by the 

estimated total principal balances across each of the 108 groups.

The behavioral models predict the quarterly probability of prepayment, default, and default severity for 

each group. Those probabilities are based on statistical estimates using historical data on individual 

mortgages originated between 2000 and 2010 and fairly standard statistical specifications.20

Calculating Incremental Refinancing 

As a first step in determining incremental refinancing attributable to the program, we run the behavioral 

models to simulate a scenario without the program (the “base case” scenario). Under those conditions, we 

record expected prepayments, defaults, and loss severities over the remaining lifetime of existing 

mortgages for each representative group. 

Next, we run the models under conditions designed to capture the incremental refinancing volumes 

expected with the program (the “program” scenario). Specifically, we remove the constraint facing 

borrowers with negative equity by assuming that all borrowers possess a LTV ratio of 50 percent, low 

enough not to create an impediment to refinancing. Also, we assume that all borrowers have a FICO score 

of 780, high enough to ensure that credit availability is not a barrier to refinancing, even under the fairly 

stringent underwriting criteria currently in effect. The assumed rates on a new mortgage reflect expected 

market conditions and a discount for the lower transaction costs charged to the borrower. The assumed 

rates also reflect a small positive premium arising from the higher financing costs typically charged by 

MBS investors for non-standard loans.21

The difference in prepayment volumes between the base case and the program model represent the 

incremental refinancing attributed to the program over the course of calendar year 2012. Those 

incremental participation rates, applied to estimated unpaid loan principal balances, determine the 

expected dollar volumes of incremental refinancing. 

In the program scenario we assume that the net effect of lower 

transaction costs and a non-standard product amounts to a 0.25 percentage point net rate reduction for 

borrowers. Thus, the rate the borrower obtains on a mortgage refinanced through the program is the 

projected mortgage rate at the date of the refinance (as per CBO's baseline economic assumptions) less 

0.25 percentage point, and hence, is only 0.25 percentage point lower than the rate in the base case 

scenario. Because the assumed transactions cost savings are small, the main factors that drive additional 

refinancing activity in the model are the loosening of FICO and LTV restrictions. 

 20 For an overview of a standard model consistent with CBO’s approach, see Appendices A through F in “Actuarial 

Review of the Federal Housing Administration Mutual Mortgage Insurance Fund (Excluding HECMs) for Fiscal 

Year 2009,” U.S. Department of Housing and Urban Development, November 2009. 21 Loans that do not meet certain standards cannot be included in the most liquid MBSs (also known as TBA, or To 

Be Announced, mortgage-backed securities).
16

Table 2. GSE and FHA Loan Groupings

GSE Population

FHA Population

Source: Bloomberg data with CBO analysis.

ALL ALL

MBS Coupon AGE (qtrs) $ TOTAL (millions) FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON

3.0 and below 8 $113 620 100 1% 710 90 1% 780 50 98%

3.5 2 $38,528 620 100 1% 710 90 8% 780 50 91%

4.0 5 $418,011 620 100 2% 710 90 8% 780 50 90%

4.5 7 $752,275 600 110 3% 700 100 10% 740 70 87%

5.0 16 $618,117 600 110 5% 700 100 10% 740 70 85%

5.5 21 $557,648 600 110 5% 700 100 10% 740 70 85%

6.0 and above 22 $506,821 578 121 8% 678 105 15% 729 80 77%

ALL ALL

MBS Coupon AGE (qtrs) $ TOTAL (millions) FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON

3.0 and below 2 $14,457 620 85 1% 710 77 1% 780 43 98%

3.5 2 $109,092 620 85 1% 710 77 8% 780 43 91%

4.0 8 $184,379 620 85 2% 710 77 8% 780 43 90%

4.5 20 $142,009 600 94 3% 700 85 10% 740 60 87%

5.0 26 $89,047 600 94 5% 700 85 10% 740 60 85%

5.5 25 $38,176 600 94 5% 700 85 10% 740 60 85%

6.0 and above 29 $22,427 579 102 8% 679 89 15% 730 68 77%

30YR

HIGH MIDDLE LOW

15YR

HIGH MIDDLE LOW

ALL ALL

MBS Coupon AGE (qtrs) $ TOTAL (millions) FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON

3.0 and below 19 $68 620 100 30% 710 90 40% 780 50 30%

3.5 2 $12,134 620 100 30% 710 90 40% 780 50 30%

4.0 3 $101,372 620 100 40% 710 90 30% 780 50 30%

4.5 5 $269,086 600 110 40% 700 100 30% 740 70 30%

5.0 9 $208,167 600 110 40% 700 100 30% 740 70 30%

5.5 18 $94,994 600 110 40% 700 100 30% 740 70 30%

6.0 and above 22 $93,475 578 121 51% 678 106 40% 729 81 9%

ALL ALL

MBS Coupon AGE (qtrs) $ TOTAL (millions) FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON FICO MTMLTV % OF COUPON

3.0 and below 1 $43 620 85 30% 710 77 40% 780 43 30%

3.5 2 $4,545 620 85 30% 710 77 40% 780 43 30%

4.0 5 $12,144 620 85 40% 710 77 30% 780 43 30%

4.5 12 $5,015 600 94 40% 700 85 30% 740 60 30%

5.0 23 $2,931 600 94 40% 700 85 30% 740 60 30%

5.5 22 $1,334 600 94 40% 700 85 30% 740 60 30%

6.0 and above 25 $1,074 579 103 51% 679 89 40% 729 68 9%

30YR

HIGH MIDDLE LOW

15YR

HIGH MIDDLE LOW
17

Table 3 summarizes the expected refinancing rates under the base case and program scenarios for the 

representative groups. Values in the table represent the unpaid balance in each group expected to refinance during 

the period of time that the program is in effect as a percent of total unpaid balance outstanding at the start of the 

program. In total, the model predicts that $428 billion of incremental refinancing would occur under the program.

Table 3. Expected Incremental Refinance Rates

GSE Population

FHA Population

Source: CBO analysis.

HIGH HIGH MIDDLE MIDDLE LOW LOW

MBS Coupon Base Case Program Base Case Program Base Case Program

3.0 and below 1% 7% 2% 7% 3% 7%

3.5 2% 10% 4% 10% 6% 10%

4.0 2% 14% 5% 14% 8% 14%

4.5 3% 20% 4% 20% 11% 20%

5.0 4% 25% 6% 25% 14% 25%

5.5 3% 23% 5% 23% 12% 23%

6.0 and above 4% 29% 6% 30% 13% 31%

HIGH HIGH MIDDLE MIDDLE LOW LOW

MBS Coupon Base Case Program Base Case Program Base Case Program

3.0 and below 3% 6% 4% 6% 3% 6%

3.5 4% 10% 6% 10% 6% 10%

4.0 5% 14% 7% 14% 8% 14%

4.5 4% 18% 7% 18% 10% 18%

5.0 4% 19% 8% 19% 11% 19%

5.5 5% 23% 9% 24% 14% 24%

6.0 and above 4% 41% 13% 43% 26% 43%

30YR

15YR

HIGH HIGH MIDDLE MIDDLE LOW LOW

MBS Coupon Base Case Program Base Case Program Base Case Program

3.0 and below 1% 6% 2% 6% 4% 6%

3.5 2% 9% 4% 9% 6% 9%

4.0 3% 15% 5% 15% 9% 15%

4.5 2% 17% 4% 17% 10% 17%

5.0 3% 18% 4% 18% 10% 18%

5.5 4% 25% 6% 25% 14% 25%

6.0 and above 4% 31% 7% 31% 14% 31%

HIGH HIGH MIDDLE MIDDLE LOW LOW

MBS Coupon Base Case Program Base Case Program Base Case Program

3.0 and below 3% 6% 4% 6% 4% 6%

3.5 4% 9% 5% 9% 6% 9%

4.0 5% 13% 7% 13% 7% 13%

4.5 7% 30% 12% 30% 17% 30%

5.0 4% 19% 7% 19% 11% 19%

5.5 5% 23% 9% 23% 14% 23%

6.0 and above 4% 31% 9% 31% 18% 31%

30YR

15YR
18

Relaxing underwriting constraints (by setting an LTV ratio of 50 percent and a FICO score of 780) for all 

borrowers under the program scenario of our behavioral models results in identical refinance rates between high, 

middle, and low risk borrowers with the same MBS coupon. Borrowers in the high and middle risk categories, 

with the highest current LTV and lowest FICO score in the base case scenario, benefit most from the program’s 

relaxed eligibility requirements (reflected in the largest increase in refinance rates between the base case and 

program scenarios). Because those groups represent a small portion of the borrower population, however, the 

greatest number of incremental refinanced loans is expected from the borrowers in the low risk category. Those 

borrowers, while less likely to be inhibited from refinancing under existing programs because of credit or LTV 

issues, may be attracted by the lower costs of the program.

Impediments to Program Participation

The estimate of incremental refinancing volume is based on data on transactions made prior to the current 

financial crisis. Projecting this behavior on a post-crisis mortgage market may not capture some of the structural 

changes that have occurred over the past few years. Although it is extremely difficult to quantify the impact of 

those changes on program participation, there are several important considerations that could affect the program 

take-up rate.

One of the key structural considerations is the ability of lenders to scale up quickly to the capacity that would be

needed to meet program demand. With relatively low origination volumes in recent years and with significant 

investments required in the servicing area to handle delinquent loans and foreclosures, many lenders may be 

unwilling to make the investments in capacity necessary to accommodate greater demand. That may be 

particularly evident if lenders are required to originate those loans without the latitude to charge normal 

refinancing fees. In addition to operational issues, lenders must also be willing to take on the liability associated 

with closing the new loan for the GSEs or FHA (generally referred to as “representations and warranties”). As 

part of program design, that liability could be reduced or eliminated to reflect the streamlined nature of the new 

loan. However, eliminating the option to “put back” the loan to the original lender (whose obligation generally 

terminates when the loan refinances) and forgoing standard representations and warranties for the lender on the 

refinanced loan leaves the risk for any errors or omissions in the loan origination process with the GSEs or FHA,

potentially increasing the expected cost of the program to the federal government.

A second consideration is the willingness for subordinate lien holders (for instance, banks that financed second 

mortgages), PMIs, and servicers to make the financial or operational concessions necessary to facilitate the 

refinancing of the existing first mortgage. For example, in many states, the subordinate lien holder must agree to 

“re-subordinate” its lien to the new, refinanced first mortgage. Similarly, the private mortgage insurer must agree 

to the terms of the refinancing if its coverage is required on the new loan (as is the case for Fannie Mae and 

Freddie Mac loans with current LTVs greater than 80 percent). Although the GSEs and FHA may be compelled to 

participate in the program, the voluntary participation of private market entities is not guaranteed. That issue is 

often cited as a factor behind low participation rates in the Administration’s HAMP and other loan-modification 

programs, where the benefits to servicers and MBS investors are not always clear-cut.

22

 22 For discussion of conflicting incentives in loan modifications, see Adelino, Manuel, Kristopher Gerardi, and Paul S. 

Willen, “Why Don’t Lenders Renegotiate More Home Mortgages? Redefaults, Self-Cures, and Securitization,” Federal 

Reserve Bank of Boston Public Policy Discussion Papers, July 2009.

However, because 

making mortgages more affordable, and thereby reducing default rates, is also in the interest of private mortgage 

insurers and second lien holders, our estimates assume third-parties will participate (after making required 

technical and operational changes to accommodate the program) rather than attempt to extract additional 

concessions in exchange for their involvement. If this assumption proves incorrect, the number of borrowers with 

second liens or private mortgage insurance able to participate in the program may be reduced significantly.
19

Third, the potential benefit to borrowers with LTVs in excess of 125 percent may be mitigated by a higher cost of 

financing those mortgages. Under one interpretation of the tax code, such mortgages may not be eligible for 

inclusion in securitizations classified as Real Estate Mortgage Investment Conduits (REMICs), a type of 

mortgage-backed security.23 As a practical matter, loans with a current LTV greater than 125 percent are 

generally ineligible for REMIC inclusion.

24

Finally, the estimate of participation is sensitive to the projected future interest rates and home prices. The path of 

short-term interest rates is a key component. If rates rise more than projected during the program (or if program 

implementation is delayed in a rising rate environment), participation will decline because fewer borrowers will 

see a benefit to refinancing at current market rates. On the other hand, rates rising less than expected will have the 

opposite effect. Short-term deviations in home prices from those projected by our models will have a less 

pronounced impact on participation. Prices rising more than anticipated may allow more homeowners to qualify 

for existing programs, lessening the need for the program. Falling prices may drive more borrowers into default, 

reducing potential participation. Similar to their effect on participation, both home prices and interest rates have a 

significant impact on the projected costs and benefits of the program.

To date, the GSEs have not securitized loans that were ineligible for 

inclusion in a REMIC, although in principle they could. If this policy remains in place, the GSEs will need to 

place all loans refinanced under the program with a current LTV greater than 125 percent in their portfolios, 

similar to loans modified under HAMP or other loan modification programs.

Costs and Benefits of the Program

A program that offers refinancing under terms and conditions that extend beyond existing programs will benefit 

borrowers through lower monthly mortgage payments resulting from lower interest rates. Both borrowers and 

credit guarantors such as the GSEs and FHA will benefit from the lower default rates created by reducing monthly 

mortgage payments for certain borrowers. However, the program is costly to MBS investors, who suffer a loss 

when the securities they hold are repaid more rapidly than in the absence of the program. Some of the investors 

are federal, creating investment losses for the federal government. Other stakeholders in the mortgage industry, 

including lenders, servicers, mortgage insurers, and ancillary service providers, will also accrue both costs and 

benefits as a result of such a program.

Benefits to Homeowners and the Economy

Refinancing at a lower interest rate generates several benefits for homeowners. First, households make lower 

interest payments per month, which is much like an increase in disposable income. Second, payments of mortgage 

principal per month are lower. Households that refinance into mortgages with longer terms than the remaining 

terms on their existing mortgages spread their payments of mortgage principal over more years and thus their 

monthly principal payments decline (although those payments extend for longer). Lower payments of mortgage 

principal provide households with greater liquidity, which helps borrowers without access to affordable credit. 

The increases in liquidity and in disposable income after mortgage interest payments lead to higher non-housing 

expenditures. In addition, the ability to make a lower monthly mortgage payment helps some portion of 

 23 REMICs are typically backed by MBSs and are structured to provide to investors payments of principal and interest with 

characteristics different from those of the underlying MBSs. 24 REMIC Regulations, §Reg. 1.860G-2
20

refinancers avoid default. Finally, both borrowers and their local communities benefit from avoiding the 

economic and social costs of the averted defaults and foreclosures.

25

Two factors affect that reduction in borrower payments: the amount by which the interest rate is reduced, and the 

maturity of the new mortgage. Under the stylized program, all new mortgages have a maturity of 30 years. The 

model predicts first-year gross cash savings from reduced mortgage payments of approximately $7.4 billion, or 

roughly $2,600 per borrower. 

A default and a resulting foreclosure have direct and indirect costs, affecting both the borrower and the local 

community. The model predicts approximately 111,000 fewer loans will default as a result of this program, in 

comparison to the approximate 4 million borrowers currently past due on their mortgages.26

Costs and Benefits to Federal Entities

The program has cost implications for a number of federal entities, including Fannie Mae and Freddie Mac, FHA, 

the Federal Reserve System, and the Treasury Department. Because of their mix of credit guarantees and portfolio 

investments, the GSEs experience both gains and losses. FHA, which does not have a portfolio, will experience 

gains from its credit guarantees. The Federal Reserve and the Treasury, with exposure through their investment in 

MBSs, will face a loss.

The analysis here reports all costs on a fair-value basis, which is an estimate of the market value of the gains or

losses from the program. In some cases, the budgetary cost would be higher or lower than the fair-value cost

because of the rules governing budgetary accounting. In particular, the fair-value approach is consistent with 

CBO’s budgetary treatment of the GSEs, but it differs from the budgetary treatment of both the Federal Reserve, 

reflected in the budget on a cash basis, and the MBS purchases of the U.S. Treasury, presented on a FCRA basis. 

With those differences in mind, reported costs in this paper are meant to provide an internally consistent measure 

of cost but not an estimate of the federal budgetary cost of a large-scale refinancing program. Because the 

proposal analyzed here is a stylized one and the estimated costs are not reported entirely according to the rules 

governing federal budget accounting, the figures in this paper do not represent a CBO cost estimate of a 

legislative proposal. (See the Appendix on the effects of fair-value and alternative budgetary treatments of credit 

programs.)

The program results in a net federal cost of $0.6 billion on a fair-value basis, but the various federal entities 

involved are affected quite differently. FHA achieves savings from reduced losses on its outstanding guarantees. 

For the GSEs, the savings from lower guarantee losses approximately offset the losses on their portfolios. The 

Federal Reserve and the Treasury experience losses on their portfolio holdings. See Table 4 for a summary of the 

estimated costs and savings.

The greatest uncertainty affecting those estimates is the volume of additional refinancing that the program would 

trigger. Changes in a variety of assumptions would affect these estimates, but the conclusion that the program has 

a net fair-value cost to the government overall is robust to a wide set of alternative assumptions. 

 25 For example, there is evidence that concentrated foreclosures depress the prices of nearby properties. See Jenny Schuetz, 

Vicki Been and Ingrid Gould Ellen,” Neighborhood effects of concentrated mortgage foreclosures,” Journal of Housing 

Economics, Volume 17, Issue 4, December 2008, pp 307-319. 26 Based on the Q4 2010 Mortgage Bankers Association National Delinquency Survey.
21

Table 4. Incremental Refinancing and Components of Federal Fair-Value Cost

Category Amount ($ billions)

Volume of incremental refinancing from program $428

Percentage of outstanding 30-year and 15-year MBSs 10%

Number of incremental loans refinanced 2.9 million

Number of defaults averted 111,000

First-year gross cash savings from reduced mortgage payments $7.4

Reduction in subsidy cost on GSE guaranteesa $2.5

Reduction in subsidy cost on FHA guaranteesa $1.4

Lost portfolio value to GSEs ($1.8)

Lost portfolio value to Federal Reserve ($2.4)

Lost portfolio value to Treasury ($0.3)

Total federal gain / (loss) ($0.6) a Reduction in subsidy costs for the GSEs and FHA are net of lost put-back option value.

Calculating Guarantee Savings 

The GSEs and FHA benefit from lower future default rates on the refinanced loans. Those savings are calculated 

based on the incremental refinance amounts predicted by the behavioral models and the differences in lifetime 

loss rates across the base case and program scenarios. For that calculation of averted losses on a given loan, the 

only difference between the two scenarios is the interest rate on the loan—without the program it is the original 

rate, and with the program it is the new market rate obtained by refinancing. (An alternative calibration takes into 

account that the new mortgage has a potentially longer lifetime and a different pattern of prepayments, defaults, 

and guarantee fee receipts. Those assumptions result in somewhat higher savings but do not change the 

conclusion that the program has a net cost to the government.) In all cases, LTVs and credit profiles reflect the 

observed indicators of the risk characteristics of borrowers.

The reduction in the fair-value cost of the GSEs’ and FHA’s guarantee obligations is based on the difference in 

the present value of net guarantee costs between the base case and program scenarios, where the price of risk is 

accounted for in the choices of rates used to calculate the value of MBSs and whole loans. In cases where the 

program allows a borrower to refinance into a lower mortgage rate, the likelihood of default will fall, lowering 

future expected costs on the loan. The savings rates calculated for each group are applied to the incremental 

refinancing volumes (calculated as described above) to determine the expected dollar volume of guarantee 

savings.

The effect on the cost of mortgage guarantees depends on revenues from fees on borrowers and other sources, as 

well as from default and recovery rates. A potentially important consideration is that a large-scale refinancing

program may negatively affect the value of the GSEs’ and FHA’s contractual right to recover money from the 

originating lender in some instances. Specifically, they may “put back” a defaulted loan to the originating lender 

if the loan was closed in violation of the lender’s representations and warranties, avoiding losses associated with 

those loans. Once a loan is refinanced, they forgo the right to put back losses associated with the original loan 

(assuming the refinanced loan does not also violate those representations and warranties). To take that effect into 

account, the estimated net guarantee savings shown here have been adjusted downward. The size of the downward 

adjustment is based on public information about put-back rates over the past few years and on settlements that 

have already occurred and that reduce future potential volume. There is considerable uncertainty associated with 

this effect, which depends on how negotiations are resolved and on legal decisions. However, potential recoveries 

from put-backs on the mortgages refinanced under the program that would not have been refinanced without the 
22

program appear to be relatively small and hence, the loss of those put-back rights imposes only a small loss on the 

GSEs and FHA (approximately $100 million in our estimate).27

Calculating Portfolio Losses 

The accelerated prepayment of MBSs that are yielding above-market interest rates results in significant losses on 

the portfolio holdings of the GSE, Federal Reserve, and Treasury portfolios. The cost is calculated as the 

difference between the current market value of the mortgage and its par or principal value, which is the amount 

received when it is prepaid. The loss estimates rely on the incremental prepayment rates described above, public 

disclosures of portfolio size and composition, and data on the market prices of the MBSs.

The total size of GSE holdings of agency MBSs, estimated to be about $540 billion, is based on information 

provided in the GSEs’ Monthly Summaries. The analysis excludes both private-label securities held in portfolio 

(loans that are not guaranteed by the GSEs are not eligible for refinancing under the program) and whole loans, 

which the model assumes do not participate. GSE whole loan holdings in portfolio comprise two main categories: 

loans purchased directly from lenders that have not been placed in MBS pools and loans modified by the GSEs as 

a result of a loss-mitigation program (also known as a “loan modification”). Loans recently purchased from 

lenders are already at market rates and would be unlikely to refinance. Similarly, recently modified loans would

have an interest rate lower than the rate obtainable under the program and are therefore unlikely to refinance 

because of it.

The Federal Reserve’s MBS Purchase Program commenced in January 2009 and ended in March 2010. The 

principal value of holdings from purchases of GSE and FHA (through Ginnie Mae securitizations) MBSs totaled 

about $899 billion as of June 2, 2011. The remaining principal value of the Treasury’s investment in similar 

agency MBSs made in response to the financial crisis totaled about $93 billion. Both the Federal Reserve and the 

Treasury are reported to have purchased recently issued lower-coupon MBSs (as opposed to older, higher-coupon 

securities) in order to maximize the effect of its purchases on interest rates on new mortgages. 

In comparison to the Federal Reserve and the Treasury, the GSEs’ portfolios include a greater share of older 

issues for which the interest rate exceeds current market rates. Because the losses due to prepayment differ 

significantly across MBS coupon and maturity pools, we infer the share of the portfolio held in different pools to 

estimate losses. While the GSEs’ Monthly Summaries do not provide that detail, public data on the total 

population of GSE MBSs outstanding and data on recent purchases by the Federal Reserve serve as benchmarks.

The GSEs’ portfolio distribution across coupon–product combinations is assumed to be at the midpoint of the 

total market portfolio and the Federal Reserve’s portfolio. This calculation is based on the assumption that the 

GSEs actively manage their portfolios and thus hold a higher percentage of more recent, lower-coupon securities 

than the market as a whole, while at the same time they hold older vintages than the Treasury and Federal 

Reserve, which purchased mortgages only during a short window of time.

We use market data from June 2011, adjusted to reflect the expected life of the security and changes in market 

interest rates at the program start date in the first quarter of 2012, to calculate a weighted average price for each 

MBS coupon–original maturity combination. Those prices represent securities that trade at both a premium (i.e., a 

price greater than 100 percent of outstanding face value) and discount (i.e., a price less than 100 percent of 

outstanding face value) to par. As a result, an incremental refinancing of a loan contained in an MBS trading 

 27 Our estimate of the value of the lost put-back option is based on the $428 billion of incremental refinancings expected from 

the program, which is limited to borrowers who are current on their existing mortgage. For the put-back option on the 

incremental participating loans to have value, the borrower must default on the loan, a violation of representations and 

warranties must be uncovered and the loan must be from a lender that has not already negotiated a settlement with the GSEs 

or FHA on violations of previously-originated loans.
23

below par represents a gain to investors (because they receive 100 percent of outstanding face value as a function 

of the refinancing) but a loan contained in an MBS trading above par generates a loss. On aggregate, the program 

creates a loss on the portfolios of federal entities because the majority of expected refinancing is in higher-coupon 

loans pooled in MBSs priced at a premium.

The final step in calculating portfolio losses is to multiply the estimated holdings in each coupon–product 

combination by the price associated with those securities by the expected incremental refinancing rates for each 

group.

Costs and Benefits to Non-Federal Stakeholders

Nearly all loans eligible for refinancing under the stylized program described above currently afford the borrower 

the opportunity to refinance without penalty under the terms and conditions of the existing loan. The goal of this 

program is not to alter the contracts associated with those existing loans but to make the refinancing opportunity 

for the borrower more readily available, less expensive, or a combination of both. However, refinancing that 

would not occur absent the program will affect a number of stakeholders beyond those with a direct budgetary 

impact. Those stakeholders include non-federal investors in MBSs guaranteed by the GSEs and by FHA. Also 

affected are lenders, loan servicers, ancillary service providers (title insurers, appraisers, settlement providers, 

etc.), local taxing authorities, and investors in second mortgages and MBSs. 

Non-Federal Investors

Investors in GSE and FHA (through Ginnie Mae) MBSs include international investors (both private and 

government), U.S. banks and other financial institutions, pension funds, life insurance companies, money market 

funds, mutual funds, and state and local governments. Like their federal counterparts, non-federal investors will 

see the fair value of their investments fall as a result of this program. Non-federal investors hold approximately 65 

percent of the outstanding MBSs assumed to be affected by the program. Those investors hold a greater 

proportion of older higher-coupon securities than federal entities and are expected to experience a 

disproportionately large fair-value loss of $13 to $15 billion.

Lenders and Other Service Providers

The effect of the program on lenders (as mortgage originators) is consistent with the effects of any refinancing on 

the entities that participate in the existing loan or the new loan. For the originator of the existing loan, a 

refinancing represents the loss of both a borrower relationship and a servicing obligation (assuming the servicing 

was not sold subsequent to the origination process). It also relieves the originator of any obligation it may have 

had with respect to representations and warranties on the existing loan. The originator of the new loan represents a 

mirror image of that situation—picking up a new customer relationship, servicing obligation, and representation 

and warranty obligation (though the nature of this obligation may be different as a result of the streamlined nature 

of the program). In addition, the new originator will earn the allowable fees for processing the new loan.

Several other parties are involved in most mortgage transactions, facilitating the closing of the loan (including 

appraisers, settlement attorneys, document preparation firms, and couriers) and taking an ongoing interest in the 

loan after closing (title insurers and servicers).

The scope and scale of additional services related to processing the new loan depend upon the specifics of the 

refinancing program. In general, the desire to reduce cost for the borrower will require that many services 

associated with a new loan be waived, curtailed, or offered at reduced cost. That desire to reduce cost is balanced 

against the goal of producing a well-documented transaction. The impact on firms that provide those services will 

depend on the extent to which they participate in these refinancings and the degree to which they are permitted to 

charge a fee commensurate with their costs.
24

The effect on servicers is similar to those described for lenders. The servicer of the existing loan will lose its 

servicing asset and customer relationship but will also be relieved of any representation and warranty obligations 

attached to the servicing process. In addition, the servicer of the refinancing will acquire a new asset, a new 

customer, and all responsibilities associated with that transaction. To the extent that servicers attract different 

proportions of the new business, some servicers will come out ahead and others will take a loss.28

In some traditional refinancing transactions, the borrower is required to pay a recordation tax or “stamp” to the 

local government. If this requirement applies to loans refinanced under the program, the local taxing authority 

will receive the benefit of this additional revenue.

Private Mortgage Insurers and Subordinate Mortgage Investors

The role of private mortgage insurers in the refinancing transaction depends upon the specific definition of the 

program. In the stylized program used for this analysis, the mortgage insurance policy attached to the existing 

loan will transfer to the new loan in a manner similar to the Administration’s HARP. Under that proposal, the

PMI retains existing coverage and receives the current monthly premium payments from the borrower. Like the 

exposure for the Federal guarantor, the PMI’s risk profile should decline as a result of the lower monthly payment 

created by the refinancing transaction. That effect is balanced by the extension of the loan term, allowing more 

time for defaults to occur and premiums to be collected for a longer period of time. The net effect of those factors 

should be an increase in the fair value of the PMI’s policy to its shareholders. There is some lost value to the PMI 

from a missed opportunity to increase premiums or coverage levels based on the current borrower and loan 

characteristics that would come from a traditional refinancing’s full underwriting.

In traditional refinancing transactions where the borrower also has a subordinate lien, the investor in that 

subordinate mortgage is often asked to re-subordinate its interest to ensure that the refinanced first mortgage

remains in primary position. It is assumed that this requirement will apply to loans refinanced under the stylized 

program. If that is the case, the value of the subordinate lien investor’s asset would be affected by many of the 

same factors discussed above, particularly the expected reduction in defaults associated with the refinanced first 

mortgage.

Macroeconomic Benefits

The program has the potential to provide economic stimulus by increasing the resources households have 

available to spend because of the reduction in the size of their mortgage payments. However, those effects would 

be partially offset by a reduction in spending by investors as a result of their losses from the program. In 

aggregate, the fair-value loss to both federal and non-federal investors is equivalent to the gain experienced by 

borrowers from the decline in their interest payments (less transaction costs for both parties). Nevertheless, 

because a significant share of investors is composed of foreigners and the U.S. government, and because private 

investors would be expected to reduce spending in response their losses by less than the increase in spending by 

borrowers in response to their lower interest payments as well as their lower mortgage principal payments, the net 

effect would be an economic stimulus. The total impact on GDP would be a multiple of the direct impact of the 

program to the extent that it stimulates additional economic activity; for instance, because additional hiring and 

investment would be needed to meet increased consumption demand. We have not quantified the potential 

stimulus in our analysis, but it is likely to be small relative to GDP while large relative to the net federal cost of 

the program.

With respect to the housing market, the overall impact of the program is also small; the 111,000 homeowners 

saved from foreclosure by virtue of lower monthly mortgage payments will have a minor impact on the path of 

 28 Firms often both lend and service loans.
25

future home prices. Because this program is directed toward current homeowners, it would do little to alleviate the 

tighter underwriting standards and increased credit pricing for purchase loans. In addition, it would not create 

much demand for homes, because all of its participants would already have at least one property. 

Sensitivity of Results to Alternative Policy Choices

The goals of a large-scale refinancing program include maximizing the participation of qualified borrowers, 

reducing the cost to those borrowers, improving the chances that they perform on the refinanced loans, and 

minimizing the negative effects on taxpayers and other stakeholders in the mortgage finance industry. Not all of 

those goals are completely compatible, requiring policymakers to make trade-offs.

One example is the inclusion of borrowers with a higher probability of default on the refinanced loan. Most 

existing programs, including HARP and the FHA’s Streamlined Refinance, require the borrower to meet certain 

LTV thresholds and to exhibit the ability to afford the payment associated with the refinanced loan. While our 

stylized program eliminates those restrictions, we can test their impact by eliminating all borrowers in our highrisk category from the eligible population. As Table 5 shows, the change has only a modest effect on program 

participation (because most borrowers expected to participate in the program due to lower fees or less restrictive 

LTV limits are outside the high-risk category) but has a significant impact on expected costs. Excluding high-risk 

borrowers eliminates much of the expected benefit on the GSEs’ and FHA’s guarantee portfolios, because the 

remaining borrowers are much less likely to default under the terms of their existing or refinanced loan. Not 

surprisingly, the change has a greater effect on the number of foreclosures averted (dropping approximately 

51 percent to 54 thousand) than on the projected annual payment reduction (dropping approximately 14 percent to 

$6.4 billion). 

Table 5. Incremental Refinancing and Components of Federal Fair-Value Cost without High Risk Loans

Category Amount ($ billions)

Volume of incremental refinancing from program $359

Percentage of outstanding 30-year and 15-year MBSs 9%

Number of incremental loans refinanced 2.4 million

Number of defaults averted 54,000

First-year gross cash savings from reduced mortgage payments $6.4

Reduction in subsidy cost on GSE guaranteesa $1.2

Reduction in subsidy cost on FHA guaranteesa $0.1

Lost portfolio value to GSEs ($1.7)

Lost portfolio to Federal Reserve ($2.0)

Lost portfolio value to Treasury ($0.1)

Total federal gain / (loss) ($2.5) a Reduction in subsidy costs for the GSEs and FHA are net of lost put-back option value.

A second policy decision is the degree to which program participants are offered an opportunity to refinance at a 

reduced cost. Reducing or eliminating certain fees in the refinancing transaction will induce some borrowers, but 

may lessen the motivation of lenders and other services providers to participate. Under our stylized program, we 

assume borrowers receive an interest rate on their refinanced mortgage that is 0.25 percentage point below the 

prevailing market rate at that time, a proxy for the reduced costs associated with the proposed program. Table 6

provides the results if that cost advantage is eliminated and borrowers are assumed to refinance at the prevailing 

market rate (including their existing guarantee fee in the form of an ongoing payment) and pay all standard 
26

refinancing fees (but other program parameters, including the ability to avoid LTV and income checks, are left 

intact). In this case, the change has only a moderate effect on program participation. However, expected total 

program losses increased by more than 80 percent (as GSE and FHA guarantee savings decreased more than 

portfolio losses were reduced) and both the number of foreclosures averted and the projected annual payment 

reduction dropped approximately 20 percent.

Table 6. Incremental Refinancing and Components of Federal Fair-Value Cost without Cost Advantage

Category Amount ($ billions)

Volume of incremental refinancing from program $386

Percentage of outstanding 30-year and 15-year MBSs 9%

Number of incremental loans refinanced 2.6 million

Number of defaults averted 86,000

First-year gross cash savings from reduced mortgage payments $6.0

Reduction in subsidy cost on GSE guaranteesa $2.0

Reduction in subsidy cost on FHA guaranteesa $1.0

Lost portfolio value to GSEs ($1.7)

Lost portfolio to Federal Reserve ($2.1)

Lost portfolio value to Treasury ($0.3)

Total federal gain / (loss) ($1.1) a Reduction in subsidy costs for the GSEs and FHA are net of lost put-back option value.

Discussion 

A well-designed and well-executed large-scale refinancing program with relatively broad eligibility criteria would 

have benefits both for borrowers with above-market interest rate mortgages and for the enterprises providing the 

credit guarantee on those same loans. Those benefits would come at a cost to those who invested in the MBSs 

backed by the loans. Some of that cost would be borne by the federal entities (the GSEs, the Federal Reserve, and 

the Treasury) that have amassed portfolios of those securities. An additional consideration is that such a program 

could be rolled out to the market relatively quickly.

A large-scale mortgage refinancing program would not address many of the problems facing the U.S. housing 

market. The significant number of borrowers who are in some stage of default would not be helped. For many 

borrowers struggling to afford their mortgages, refinancing at a market rate might not provide the level of 

payment relief necessary to avoid an eventual default. In those circumstances, a payment reduction modification 

(such as those offered by HAMP) might be more likely to forestall a default.

A further issue is the large number of borrowers with significant negative equity in their homes. Negative equity 

affects the broader economy in several ways: by leaving borrowers susceptible to delinquency caused by life 

events (such as illness, divorce, or short-term disruptions in income) that could otherwise be solved by a 

traditional refinancing or sale of the home; by creating an incentive for some borrowers to “strategically” default;

and by restricting labor mobility for homeowners who are restricted in their ability to move outside their local 

market for employment. It also may cause homeowners to postpone home sales motivated by the desire to change 

residences. Once again, a refinancing program would do little to address that situation. While providing an 

opportunity for some homeowners to take advantage of lower rates by waiving constraints on current LTV, any 

program that does not include principal forgiveness would not significantly address the problems associated with 

negative equity.
27

Appendix: Fair Value and Alternative Budgetary Treatments of Credit Programs

The budgetary cost of a large-scale mortgage refinancing program would differ from the cost on a fair-value basis, 

which is the methodology used in this analysis. The federal budget is primarily a record of the cash spent on 

federal activities in a year. However, for certain contracts that obligate the government to make or receive 

payments that extend for a longer period, the budget records accruals rather than cash outlays. Accruals measure 

the value of projected net future payments on a discounted present-value basis. The Fair Credit Reporting Act 

(FCRA) specifies that the costs of the government’s direct loans and loan guarantees—such as those made by 

FHA—are to be reported on an accrual basis.29 It requires that Treasury rates be used to discount projected cash 

flows, and excludes administrative costs associated with the loans (those costs are recorded in the budget 

separately on a cash basis).30

Fair-value accounting—an alternative method of accrual accounting that recognizes that the government’s 

assumption of financial risk has costs for taxpayers that exceed the average amount of losses that would be 

expected from defaults—has made several appearances in the federal budget process. The legislation that 

established the Troubled Asset Relief Program specified the use of a fair-value approach—in particular, that the 

estimated cost of the program’s obligations be recorded in the budget on a FCRA basis but that the discount rate 

used for such estimates be adjusted for the cost of market risk.31 In addition, CBO uses a fair-value approach to 

incorporate the cost of Fannie Mae and Freddie Mac into its baseline budget projections.32 And in recent years, 

CBO has provided supplementary information to the Congress about the fair-value cost of several federal credit 

and insurance programs, including FHA’s single-family mortgage insurance program.33

Both the FCRA approach and the fair-value approach rely on the same projections of future cash flows. With 

accrual accounting, expenses are recorded when they are incurred and revenues when they are earned, rather than 

when payments are made or received. Both approaches take into account the lifetime cost of a direct loan or loan 

guarantee made in a given year (including the expected cost of defaults, net of fees collected). But fair-value’s 

inclusion of financial risk (market risk) is a key distinction from estimates produced using the FCRA 

methodology. In practice, the main difference between FCRA estimates and fair-value estimates is the effective 

discount rates used (either explicitly or implicitly) to calculate the present value of future guarantee costs and 

receipts: For FCRA estimates, projected cash flows are discounted using interest rates on Treasury securities, but 

fair-value estimates are calculated using discount rates that incorporate a premium for market risk. Market risk is 

the component of financial risk that investors cannot avoid by diversifying their portfolios. Investors require 

additional compensation for market risk—known as a market risk premium—because investments exposed to 

such risk are more likely to have low returns when the economy as a whole is weak and resources are scarce and 

highly valued. That premium is reflected in the fact that assets carrying more market risk have higher expected 

returns and lower prices.

For a large-scale mortgage refinancing program, some of the costs would appear in the budget on a cash basis, 

others on a fair-value basis, and still others on a FCRA basis. The activities of the Federal Reserve are reported in 

the budget on a cash basis. Accelerated prepayment of the MBSs the Federal Reserve holds would lower its 

 29 2 U.S.C. §661a (5) (B), (C), 104 Stat. 1388-610 30 2 U.S.C. §661a (5) (E), 104 Stat. 1388-610 and 2 U.S.C. §661a (5) (A), 104 Stat. 1388-610 31 Section 123 of the Emergency Economic Stabilization Act of 2008, Division A of Public Law 110-343, 12 U.S.C. §5232 

(6) 122 Stat. 3790

32 See “CBO’s Budgetary Treatment of Fannie Mae and Freddie Mac,” Congressional Budget Office, January 2010. 33 For a more complete comparison of FCRA and fair-value budgetary treatment for mortgage guarantees, see “Accounting 

for FHA’s Single-Family Mortgage Insurance Program on a Fair-Value Basis,” Congressional Budget Office, May 2011.
28

income and hence its remittances to the Treasury. The MBS holdings of the Treasury are accounted for under 

FCRA. 

The Office of Management and Budget treats the Federal Reserve and Treasury transactions similarly to CBO, but 

it does not consider Fannie Mae or Freddie Mac to be federal entities. Hence it records transactions with the GSEs 

on a cash basis.