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STRENGTHENING OVERSIGHT AND 

PREVENTING FRAUD IN FHA AND 

OTHER HUD PROGRAMS 

HEARING 

BEFORE THE

SUBCOMMITTEE ON 

OVERSIGHT AND INVESTIGATIONS 

OF THE

COMMITTEE ON FINANCIAL SERVICES 

U.S. HOUSE OF REPRESENTATIVES 

ONE HUNDRED ELEVENTH CONGRESS 

FIRST SESSION 

JUNE 18, 2009 

Printed for the use of the Committee on Financial Services 

Serial No. 111–46 

( 

(II) 

HOUSE COMMITTEE ON FINANCIAL SERVICES 

BARNEY FRANK, Massachusetts, Chairman 

PAUL E. KANJORSKI, Pennsylvania 

MAXINE WATERS, California 

CAROLYN B. MALONEY, New York 

LUIS V. GUTIERREZ, Illinois 

NYDIA M. VELA ́ ZQUEZ, New York 

MELVIN L. WATT, North Carolina 

GARY L. ACKERMAN, New York 

BRAD SHERMAN, California 

GREGORY W. MEEKS, New York 

DENNIS MOORE, Kansas 

MICHAEL E. CAPUANO, Massachusetts 

RUBE ́ N HINOJOSA, Texas 

WM. LACY CLAY, Missouri 

CAROLYN MCCARTHY, New York 

JOE BACA, California 

STEPHEN F. LYNCH, Massachusetts 

BRAD MILLER, North Carolina 

DAVID SCOTT, Georgia 

AL GREEN, Texas 

EMANUEL CLEAVER, Missouri 

MELISSA L. BEAN, Illinois 

GWEN MOORE, Wisconsin 

PAUL W. HODES, New Hampshire 

KEITH ELLISON, Minnesota 

RON KLEIN, Florida 

CHARLES WILSON, Ohio 

ED PERLMUTTER, Colorado 

JOE DONNELLY, Indiana 

BILL FOSTER, Illinois 

ANDRE ́ CARSON, Indiana 

JACKIE SPEIER, California 

TRAVIS CHILDERS, Mississippi 

WALT MINNICK, Idaho 

JOHN ADLER, New Jersey 

MARY JO KILROY, Ohio 

STEVE DRIEHAUS, Ohio 

SUZANNE KOSMAS, Florida 

ALAN GRAYSON, Florida 

JIM HIMES, Connecticut 

GARY PETERS, Michigan 

DAN MAFFEI, New York 

SPENCER BACHUS, Alabama 

MICHAEL N. CASTLE, Delaware 

PETER T. KING, New York 

EDWARD R. ROYCE, California 

FRANK D. LUCAS, Oklahoma 

RON PAUL, Texas 

DONALD A. MANZULLO, Illinois 

WALTER B. JONES, JR., North Carolina 

JUDY BIGGERT, Illinois 

GARY G. MILLER, California 

SHELLEY MOORE CAPITO, West Virginia 

JEB HENSARLING, Texas 

SCOTT GARRETT, New Jersey 

J. GRESHAM BARRETT, South Carolina 

JIM GERLACH, Pennsylvania 

RANDY NEUGEBAUER, Texas 

TOM PRICE, Georgia 

PATRICK T. MCHENRY, North Carolina 

JOHN CAMPBELL, California 

ADAM PUTNAM, Florida 

MICHELE BACHMANN, Minnesota 

KENNY MARCHANT, Texas 

THADDEUS G. McCOTTER, Michigan 

KEVIN McCARTHY, California 

BILL POSEY, Florida 

LYNN JENKINS, Kansas 

CHRISTOPHER LEE, New York 

ERIK PAULSEN, Minnesota 

LEONARD LANCE, New Jersey 

JEANNE M. ROSLANOWICK, Staff Director and Chief Counsel 

(III) 

SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

DENNIS MOORE, Kansas, Chairman 

STEPHEN F. LYNCH, Massachusetts 

RON KLEIN, Florida 

JACKIE SPEIER, California 

GWEN MOORE, Wisconsin 

JOHN ADLER, New Jersey 

MARY JO KILROY, Ohio 

STEVE DRIEHAUS, Ohio 

ALAN GRAYSON, Florida 

JUDY BIGGERT, Illinois 

PATRICK T. MCHENRY, North Carolina 

RON PAUL, Texas 

MICHELE BACHMANN, Minnesota 

CHRISTOPHER LEE, New York 

ERIK PAULSEN, Minnesota 

(V) 

C O N T E N T S 

Page 

Hearing held on: 

June 18, 2009 .................................................................................................... 1 

Appendix: 

June 18, 2009 .................................................................................................... 17 

WITNESSES 

THURSDAY, JUNE 18, 2009 

Berenbaum, David, Executive Vice President, National Community Reinvestment Coalition ...................................................................................................... 11 

Donohue, Kenneth M., Sr., Inspector General, U.S. Department of Housing 

and Urban Development ...................................................................................... 5 

Kittle, David G., CMB, Chairman, Mortgage Bankers Association ..................... 9 

Nunnink, Kevin K., Chairman, IRR-Residential, LLC, and Chairman, Integra 

Realty Resources .................................................................................................. 7 

Pellegrini, Frank, President, Prairie Title, on behalf of the American Land 

Title Association (ALTA) ..................................................................................... 8 

Savitt, Marc, CRMS, President, National Association of Mortgage Brokers ...... 10 

APPENDIX 

Prepared statements: 

Moore, Hon. Dennis .......................................................................................... 18 

Berenbaum, David ............................................................................................ 20 

Donohue, Kenneth M., Sr. ............................................................................... 39 

Kittle, David G. ................................................................................................. 58 

Nunnink, Kevin K. ........................................................................................... 67 

Pellegrini, Frank ............................................................................................... 69 

Savitt, Marc ...................................................................................................... 85 

ADDITIONAL MATERIAL SUBMITTED FOR THE RECORD

Moore, Hon. Dennis: 

Written statement of the U.S. Department of Housing and Urban Development ........................................................................................................... 95 

Written statement of the National Association of Realtors .......................... 100 

(1) 

STRENGTHENING OVERSIGHT AND 

PREVENTING FRAUD IN FHA AND 

OTHER HUD PROGRAMS 

Thursday, June 18, 2009 

U.S. HOUSE OF REPRESENTATIVES, 

SUBCOMMITTEE ON OVERSIGHT

AND INVESTIGATIONS, 

COMMITTEE ON FINANCIAL SERVICES, 

Washington, D.C. 

The subcommittee met, pursuant to notice, at 10:03 a.m., in room 

2128, Rayburn House Office Building, Hon. Dennis Moore [chairman of the subcommittee] presiding. 

Members present: Representatives Moore, Lynch; and Biggert. 

Also present: Representative Posey. 

Chairman MOORE OF KANSAS. Good morning. Welcome to the 

Committee on Financial Services, Subcommittee on Oversight and 

Investigations. This subcommittee will come to order. 

Our hearing this morning is entitled, ‘‘Strengthening Oversight 

and Preventing Fraud in FHA and other HUD Programs.’’ I would 

like to welcome my distinguished colleague and the ranking member, Judy Biggert, Congresswoman Biggert. And we might have 

some other people show up, but we just got word that there are 

going to be 28 votes in about 15 or 20 minutes. So I doubt that we 

can get all of this in, in the next few minutes, but we will move 

as quickly as we can here. 

I would like to start my opening statement if that is all right. 

And if there is time for Mrs. Biggert to complete her opening statement, then so be it. 

This hearing of the Subcommittee on Oversight and Investigations of the House Financial Services Committee will come to 

order. Our hearing this morning is entitled, ‘‘Strengthening Oversight and Preventing Fraud in FHA and other HUD Programs.’’ 

We will begin this morning’s subcommittee hearing with members’ opening statements, up to 10 minutes per side, and then we 

will hear testimony from our witnesses. After that, members will 

each have 5 minutes to question witnesses. 

Without objection, all members’ opening statements will be made 

a part of the record. 

Without objection, I ask that written testimony from the Department of Housing and Urban Development and the National Association of Realtors be entered into the record. 

I now recognize myself for up to 5 minutes for an opening statement. 

2 

On April 27th, I hosted a press conference at the Federal Courthouse in Kansas City, Kansas, with Missouri Attorney General 

Chris Koster, Kansas Attorney General Steve Six, as well as the 

local FBI Supervisory Special Agent and a Special Agent from the 

Office of the Inspector General from HUD. At that event, our goal 

was to raise public awareness of the mortgage fraud schemes that 

have been going on. 

In the current economic environment, too many homeowners are 

encountering significant difficulty in making their mortgage payments. Too many are at risk of losing their homes. There are a 

number of great people and resources out there to help homeowners work with their lenders so they can meet their mortgage 

obligations. Unfortunately, as a former district attorney, I know all 

too well there are also people out there who will exploit weakness 

and prey on the fear of others. 

Over the last few months, we have seen an increase in the number of fraudulent mortgage loan schemes that take advantage of 

those homeowners in desperate situations. Under the pretense of 

helping homeowners modify their mortgage obligations, these 

schemes result in the loss of money, equity, and in many cases the 

home itself. We often think of robbery as taking place with a knife 

or a gun, but these thieves instead come with a smile, a handshake, and a ballpoint pen, ultimately leaving a family in deeper 

trouble. 

Through my role as chairman of the Financial Services Oversight 

and Investigations Subcommittee, I am determined to ensure that 

local, State, and Federal law enforcement agencies have all the resources and tools they need to prosecute these horrible thieves. 

That is why I was a cosponsor of the Fight Fraud Act, which was 

renamed the Fraud Enforcement and Recovery Act by the Senate. 

No matter what you call it, this legislation is important. It 

strengthens the accountability standards for financial, mortgage 

lending, and securities agents and institutions, and authorizes additional funds for the Department of Justice, the FBI, HUD’s Inspector General, and other Federal agencies so they can hire the 

investigators they need to examine and prosecute fraudulent activity. 

Ranking Member Judy Biggert was a lead sponsor of the bill as 

well, and I would like to commend her for all the work she has 

done over the years fighting mortgage fraud. I am sure she shares 

my sentiment that I was pleased when President Obama signed 

this important legislation into law. 

One of the issues we will be focusing on today as we consider 

strong oversight of HUD is the role of FHA and its rapid expansion 

of lending in the mortgage market. Even after the subprime market collapse, FHA has continued to provide mortgage credit to responsible borrowers. But we must be vigilant to ensure that the 

same bad actors who contributed to the housing crisis don’t make 

their way into the FHA program. 

In addition to the Fraud Enforcement and Recovery Act, President Obama also signed into law the Helping Families Save Their 

Homes Act. These two new laws improve FHA requirements and 

give the FHA more authority to keep bad actors out of the FHA 

program and provide additional enforcement tools to police those 

3 

lenders who employ false or misleading tactics. In fact, just last 

week HUD announced they suspended three lenders from the FHA 

based on evidence of serious violations under HUD’s regulations. 

Another area of concern is the use of reverse mortgages that are 

primarily used by seniors. I agree with the Comptroller of the Currency, John Dugan, who recently raised a red flag on these reverse 

mortgages and noted that closer Federal oversight may be necessary to protect the FHA and homeowners. 

I am also interested in learning more about the need for accurate 

and independent appraisals, and the role appraisals currently play 

with respect to FHA-insured loans. 

If there is one lesson we have learned from the financial crisis, 

it is that we need to eliminate conflicts of interest and strengthen 

the integrity of any valuation process, everything from credit rating 

agencies to appraisals. I look forward to hearing from our witnesses on these and other important oversight issues. 

I will conclude my remarks by reminding everyone to be on high 

alert for mortgage fraud. If you or someone you know is suspicious 

of or unsure if someone is legitimately trying to help, please contact local law enforcement and let them know so they can investigate. It is imperative that we protect ourselves, our neighbors, 

and put those people preying on the victims of this housing crisis 

behind bars. 

I now recognize our distinguished ranking member of the subcommittee, my colleague and friend from Illinois, Mrs. Biggert. 

Mrs. BIGGERT. Thank you very much, Chairman Moore, and 

thank you for scheduling this hearing today on mortgage fraud. 

Some years ago, the Chicago Tribune published a series that revealed that gangs in the Chicago area were increasingly turning to 

mortgage fraud. They found it easier and more lucrative, believe it 

or not, than selling drugs. And it turns out that the gangs were not 

alone. Everyone, it seems, was in on the act. 

Earlier this year, a U.S. attorney in Chicago, Patrick Fitzgerald, 

brought mortgage fraud indictments against two dozen players. 

They are brokers, accountants, loan officers, and processors and attorneys. So mortgage fraud comes in all sizes and shapes. Scam 

artists inflate appraisals, flip properties, and lie about information, 

including income and identity on loan applications. Some use the 

identity of deceased persons to obtain mortgages. And other desperate thieves bilked the most vulnerable homeowners and seniors 

in dire financial straits out of their homes and home equity. 

Let’s face it; I think this is just the tip of the iceberg. And as we 

in Congress work to get the economy back on track and credit flowing again, we have to address what was the root of the mortgage 

meltdown in the first place, and that was mortgage fraud. Mortgage fraud is at the root of the meltdown that has undermined our 

housing market and contributed to this economic downturn. 

To restore confidence in the home buying process, it is critical 

that we provide our investigators and prosecutors the tools and resources that they require to accomplish their mission and put bad 

actors behind bars. 

As a former real estate attorney, and a member of the House 

Committee on Financial Services, I have seen firsthand the devastating effect of mortgage fraud. It has plagued our financial sysVerDate Nov 24 2008 18:26 Oct 08, 2009 Jkt 052402 PO 00000 Frm 00009 Fmt 6633 Sfmt 6633 K:\DOCS\52402.TXT TERRIE
4 

tem and economy. Most tragically, it has cost millions of American 

families their houses, and required taxpayers to commit trillions of 

their hard-earned dollars to prop up the financial industry. It is 

just not fair to the good actors in the industry and the 90 percent 

of homeowners who are paying their mortgages on time. 

According to the FBI, its mortgage fraud caseload increased by 

237 percent in the last 5 years, and investigations more than doubled in 3 years. During a 12-month period ending in 2008, mortgage fraud reports increased by 44 percent, reaching over 63,000 

reports, with predictions of up to $25 billion in losses. 

That said, I am not surprised that, with FHA’s significant increase in market share, that fraud has quickly followed. And I did 

introduce several bills, starting in 2007. Several passed the House, 

and then went over to the Senate, where somehow they got lost. 

And so we kept introducing and introducing, and finally went to 

the Judiciary Committee, and put the mortgage fraud into a bill 

that was introduced by Chairman Conyers and Chairman Moore 

and other members. And this was H.R. 1748, the Fight Fraud Act, 

which was the House version of Senate 386. And with that, we 

both had the ability to go to the White House while this bill was 

signed into law by the President. 

So as we work to pinhole loopholes and close them as we work 

to modernize the financial laws and regulations, it is also our duty 

to supply Federal law enforcement with the tools and resources 

that they need. And in addition, I think it is critical that we hold 

a hearing to learn more about the kinds of technology that can be 

used to increase transparency in the mortgage process to quickly 

flag illegal activity and apprehend the perpetrators. 

So, Chairman Moore, I would really like to request that we hold 

a hearing on technology, which I think would be helpful to this. By 

increasing the transparency in the process through technology, this 

would help. 

So with that, I would like to thank today’s witnesses and my colleagues on the committee for their commitment to one of the most 

important issues today. 

Chairman MOORE OF KANSAS. Thank you to my ranking member. 

And I really appreciate her service on the committee and the insight she brings to this. 

I want to say, very quickly here, we have received some unpleasant information, which is that at about 10:15, 28 votes are going 

to be called. I don’t know, this was not planned, we certainly didn’t 

know about this, but I want to introduce at least three of the witnesses who traveled here first. And we may have to take written 

testimony from the others. If we are going to be gone for 2 hours 

over there voting, which may be the case, seriously—I would love 

to say differently—but the problem is that Secretary Geithner is 

coming at 1 p.m., so we need to be ready for him. 

I want to introduce Mr. Kenneth Donohue, the Inspector General 

for the Department of Housing and Urban Development. During 

the savings and loan crisis, Mr. Donohue served as Assistant Director in the Office of Investigations in the RTC. 

And I am going to shorten the introductions right now, and I 

hope all the witnesses understand. I am not trying to slight anybody, but we have to move along here. 

5 

Mr. Kevin Nunnink—I invited him—who is chairman of the IRRResidential and chairman, Integra Realty Resources, is from Kansas, and he will be testifying as well. 

We are going to ask Mr. Pellegrini to testify. And would you like 

to introduce Mr. Pellegrini very quickly? 

Mrs. BIGGERT. Yes. I would like to welcome from Chicago a fellow lawyer, Mr. Frank Pellegrini. He is the founder, president, and 

chief executive officer of Prairie Title Services in Oak Park, and 

serves many of my constituents in the 13th Congressional District. 

And he is a principal of the law firm of Pellegrini and Cristiano, 

a general practice firm that specializes in real property law, business formation and counseling, and estate planning. Welcome. 

Chairman MOORE OF KANSAS. Thank you. I am not going to introduce the other witnesses right now, and I apologize for that. I 

am not trying to slight anybody, but I hope you understand. We 

want to get moving here so we can move as quickly as possible. 

Without objection, the written statements of all the witnesses will 

be made a part of the record. You will each be recognized for a 5- 

minute statement. We are going to start with you, Mr. Donohue. 

And please, I am not trying to slight the other witnesses by not 

introducing you, but I hope you understand why I am doing this. 

Mr. Donohue, please. You have 5 minutes, sir. 

STATEMENT OF KENNETH M. DONOHUE, SR., INSPECTOR GENERAL, U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 

Mr. DONOHUE. Thank you, Chairman Moore, Ranking Member 

Biggert, and members of the subcommittee. I appreciate the opportunity to testify on the role of FHA in addressing the housing crisis, as well as other HUD-related topics. Through our work in auditing and investigating many facets of the FHA program over the 

course of many years, we have had concerns regarding FHA’s systems and infrastructure to adequately perform its current requirements. This was expressed by the OIG to the FHA prior to the current influx of loans and to the numerous proposals that expand its 

reach. We remain keenly interested in FHA’s ability and capacity 

to oversee newly generated businesses. 

The past year-and-a-half have certainly produced a lot of 

changes. With the collapse of the subprime market, FHA has seen 

a dramatic increase in new businesses. The Housing and Economic 

Recovery Act created a program to enable FHA to refinance the 

mortgages of at-risk borrowers and authorize changes to the Home 

Equity Conversion Mortgage program that will enable more seniors 

to tap into their home equity. The volume of single-family loans 

has increased by a tripling from $59 billion in 2007 to over $180 

billion in 2008. FHA’s share of insured endorsements has increased 

from 24 percent to 63 percent, which includes home sales and refinances. 

Though HUD is hiring some new personnel, we believe there is 

a critical need for more resources for FHA to enhance its IT systems, to increase its personnel to deal with escalating and processing requirements, to increase its training to maintain the workforce with the necessary skills, to oversee the numerous contractors 

it maintains, and to increase its oversight of all critical front-end 

6 

issues, including areas such as the appraisal and underwriting 

process. 

We are gratified the new penalty provision we helped craft was 

inserted into the HERA bill. The statute now creates a penalty for 

committing fraud against FHA programs, and it will be a useful 

tool for prosecutors and the law enforcement community to employ. 

We are also very pleased that many of the provisions we advocated to Congress to improve internal control process and enhance 

penalties were incorporated both in the Fraud Enforcement and 

Recovery Act and the Helping Families Save Their Home Act. 

The Secretary also announced a number of new transformations, 

initiatives designed to address some of the concerns we are raising. 

The results of the last actuarial study shows that HUD has sustained significant losses in its single family program, making a robust program’s reserves smaller. As of September 30, 2008, the 

fund’s economic value was an estimated $12.9 billion, an almost 40 

percent drop from over $21 billion the year before. That represents 

3 percent of the mortgages insured by the FHA. Although above 

the 2 percent ratio required by law, it is well below the 6.4 percent 

ratio at the same time last year. 

If more pessimistic assumptions are factored in, the ratio could 

dip below 2 percent in succeeding years, requiring an increase in 

premiums or congressional appropriations intervention to make up 

the shortfall. 

As the Department is in the process of reforming its annual actuarial reviews, it is critical that assumptions used to drive the current estimates of the health of the fund be supportable. 

Among many different areas we have reviewed, we have found 

the FHA needs to improve its internal control structure. Our audit 

over the FHA appraisal roster identified weaknesses in the quality 

control review and the monitoring of that roster. Results from a 

number of other audits have noted significant lender underwriting 

deficiencies and other operational irregularities. 

The tightening credit market has increased FHA’s position as a 

loan insurer. And with that is coming increases in lender-brokers 

seeking to do business with the Federal program, and a concern regarding some of these loan originators. 

For example, we currently have under investigation several FHA 

lenders who were also lenders in the subprime market. FHA lender 

approval increases 525 percent in the last 2-year period. Newly 

signed legislation mandates an enhanced eligibility approval process, and we look forward to its implementation. 

We recently completed inspection of the Mortgage Review Board 

enforcement action and its effectiveness in resolving cases of serious noncompliance with FHA regulations, particularly during this 

period of significant change in the housing market. Again, the new 

legislation contains some provisions to strengthen this board, an 

important recommendation from our inspection. 

Another area of concern is the growing HECM, or reverse mortgage program. We are aware that the larger loan limits can be attractive to exploiters of the elderly, whether it be by third parties, 

or even family members who seek to strip equity from seniors. Due 

to the vulnerability of the population this program serves, we are 

also concerned about evasion of statutory counseling requirements. 

7 

Finally, since you are about to undertake financial regulatory reform shortly, I think it is important to raise a few issues. The fact 

that our nationwide mortgage lending system is fragmented, with 

separate players embracing different requirements, creates opportunities for waste, fraud, and abuse that a more unified approach 

could potentially mitigate. We think it would be beneficial for the 

FHA to come together more significantly, in a unified lender oversight consortium with Fannie Mae, Freddie Mac, the FDIC, and 

Ginnie Mae, in order to create standardized forms. 

Chairman MOORE OF KANSAS. Excuse me, Mr. Donohue. I apologize. We are going to have to wind up, and your written statement 

will be made a part of the record. I am going to move on to the 

other two witnesses and then to the other three for a brief statement as well, if that is okay. And I apologize for this. This was not 

planned at all. 

[The prepared statement of Inspector General Donohue can be 

found on page 39 of the appendix.] 

Chairman MOORE OF KANSAS. At this point, the Chair recognizes 

Mr. Nunnink. And everybody’s statements will be made part of this 

record. 

STATEMENT OF KEVIN K. NUNNINK, CHAIRMAN, IRR-RESIDENTIAL, LLC, AND CHAIRMAN, INTEGRA REALTY RESOURCES 

Mr. NUNNINK. Thank you. Chairman Moore, Ranking Member 

Biggert, and members of the subcommittee, thank you for inviting 

me to testify today. 

As a real estate appraiser for 30 years, I appreciate this opportunity to speak on an important topic critical to restoring the confidence in the real estate mortgage industry. I am chairman of both 

Integra Realty Resources and IRR-Residential, and we have a thousand licensed appraisers working throughout the United States. 

Sound mortgage underwriting includes two separate but equally 

important components: First, a borrower’s ability to pay as evidenced by their income and credit score; and second, sufficient 

value of the real estate to support the loan type, as evidenced by 

the appraised value. It should be noted that of all the professionals 

involved in the mortgage origination process, the appraiser is frequently the only professional who visits the property implicitly for 

the purpose of providing due diligence for their lender client. He 

inspects the property and makes sure the property has sufficient 

value to support the intended loan. Appraisers are licensed and 

professionally trained to value real estate, and must meet education and experience requirements. 

Appraiser separation is particularly important in today’s mortgage industry, where virtually all mortgage originators sell their 

mortgage paper to the secondary market, and thereby hold minimal 

long-term risk. 

An independent appraiser makes it much more difficult to initiate mortgage fraud. An independent appraiser serves as the safeguard for the protection of the current and future parties to the 

loan transaction, including the borrower, the originating lender, 

the secondary market participant, and as we are now seeing, the 

taxpayer. 

8 

Any effort to circumvent the independence of the appraised value 

heightens mortgage risk. Because of the housing slump and corresponding disruption in the credit markets over the past couple of 

years, there have been a number of initiatives, legislatively and by 

regulation, increasing the separation between the contingent fee 

real estate mortgage professional and the appraisal process. We 

support those efforts. 

Congress appropriately restricted this type of influence in 

FIRREA in 1989, but because mortgage bankers and brokers were 

not regulated by the FDIC, they did not have to provide separation 

between the appraisal process and the mortgage originator. The 

Fraud Enforcement and Recovery Act of 2009 appropriately provided further regulation upon these nontraditional bank lenders. 

There have been two structural conflicts of interest in the appraisal process: one, loan originators selecting and regulating the 

volume of work to the appraiser; and two, real estate mortgage 

companies providing bundled services, including appraisal, whose 

primary goal is to drive EBITDA, is contingent upon a successful 

loan closing. In both cases emphasis is upon the loans, not protecting the independence of the appraisal process. 

We were disappointed when the final version of the Home Valuation Code of Conduct gave a pass to those companies, lenderowned or not, that also provide title insurance, loan closing services, etc. In those cases, the company’s ability to receive the title 

and closing fees is contingent upon the loan going forward, which 

in part is conditioned upon the appraised value process they manage, and an inherent conflict of interest. 

Chairman MOORE OF KANSAS. Excuse me, Mr. Nunnink. I apologize, but we are going to have to wind up with that. And we will 

receive your written statement in the record. 

Mr. NUNNINK. Thank you, Mr. Chairman. 

[The prepared statement of Mr. Nunnink can be found on page 

67 of the appendix.] 

Chairman MOORE OF KANSAS. And I want to recognize the other 

witness who traveled to come here. Then we are going to take 2- 

or 3-minute statements from each of the other witnesses if we have 

time. Votes have not yet been called yet. 

Mr. Pellegrini, if you would please. And again, please forgive 

this. We did not plan it this way. 

STATEMENT OF FRANK PELLEGRINI, PRESIDENT, PRAIRIE 

TITLE, ON BEHALF OF THE AMERICAN LAND TITLE ASSOCIATION (ALTA) 

Mr. PELLEGRINI. Thank you, Mr. Chairman. Good morning, 

Ranking Member Biggert, and distinguished subcommittee members. I am a member of the board of governors of the American 

Land Title Association, which I am here today to represent. 

ALTA is the national association for the title industry, representing nearly 3,000 member companies, with more than 100,000 

employees, including title insurers, title insurance agents, abstracters, and attorneys that operate in every State and county throughout the United States. 

In my hometown of Chicago, as in many large urban areas, the 

proliferation of mortgage fraud activities is particularly disturbing. 

9 

As Mrs. Biggert pointed out, the profile of the typical Chicago gang 

leader has evolved into a picture of a graying, suburban technology-friendly convict overseeing operations as diverse as mortgage fraud and drug dealing. 

This form of criminal activity is spreading. Fraud, in fact, is the 

second leading cause of title claims, so we track it very closely. Our 

experience dictates that mortgage fraud schemes change with the 

economy. In a more robust economy, we witnessed that claims involve inflated values. As prices have fallen and equity has dried up, 

we now see loan-slamming claims. Additionally, with large numbers of mortgage defaults, short-sale mortgage fraud claims are becoming more prevalent. 

Title professionals enjoy a unique vantage point from which to 

observe, identify, and thwart instances of fraud. We are the independent third party to the transaction, whose only interest is to the 

integrity of the transaction and the protection of our customers. 

Through training and experience, we hone our ability to spot improper transactions every day. We look for a number of mortgage 

fraud indicators, including earnest money deposit that comes from 

someone other than the borrower, or lack of information about the 

source of the deposit; similar carry-back documents that are not 

being disclosed to the lender; payments to third parties that will 

not appear on the HUD settlement statement; wide swings in the 

mortgage amount; recent sales with increases in price, and checks 

to others at closing, which could be a sign of flipping; substitution 

of sales contract for a higher amount; the signing of blank documents, and changes or increases in the purchase price. 

As settlement service providers, we prevent fraud by carefully 

checking identification. In fact, we know of a case in which a caregiver stole the information of an elderly gentleman whom he 

worked for by merely acquiring the driver’s license and replacing 

the picture on it. The caregiver then applied for a mortgage refinance and walked away with $65,000. In this case, a check of the 

birth date would have been a tip-off that something was wrong. We 

also prevent fraud by knowing our customers. 

Chairman MOORE OF KANSAS. Mr. Pellegrini, I apologize to you, 

too. If we can, we are going to give each of the other witnesses 2 

minutes to try to summarize their testimony. Then we are going 

to start with some questions. All of your written statements will be 

received for the record. 

[The prepared statement of Mr. Pellegrini can be found on page 

69 of the appendix.] 

Chairman MOORE OF KANSAS. Mr. Kittle. And again, please accept our apologies. Mr. Kittle, if you would, please, sir. 

STATEMENT OF DAVID G. KITTLE, CMB, CHAIRMAN, 

MORTGAGE BANKERS ASSOCIATION 

Mr. KITTLE. Thank you, Mr. Chairman. 

FHA is a program that is vital to the American home buyers. It 

is one that is important to me personally, as I purchased my first 

home in 1978 with the FHA program. Currently, FHA is experiencing a rebirth, and I want to preface my remarks this morning 

with a direct appeal to Congress that if we don’t take this opportunity to be proactive and get FHA the resources it needs, the reVerDate Nov 24 2008 18:26 Oct 08, 2009 Jkt 052402 PO 00000 Frm 00015 Fmt 6633 Sfmt 6633 K:\DOCS\52402.TXT TERRIE
10 

cent reemergence of FHA won’t last long. We have a chance to prevent future problems, and we must start today. 

First and foremost, we need to give FHA the resources it needs 

to operate in an increasingly nimble and high-tech real estate finance industry. Its market share has risen from 3 to 30 percent 

virtually overnight, but it is still hampered by outdated technology, 

and its staff is stretched dangerously thin. 

The solution is fairly straightforward. Under HERA, Congress 

has already authorized $25 million per year for staffing and technology upgrades. We now need to work together to make sure this 

funding is appropriated. 

We also need to make sure Ginnie Mae has the resources it 

needs to keep pace with the spike in government lending. From 

2007 to 2008, its issuance has increased from $85 billion to $221 

billion, with a staff of 65. That needs to be increased to at least 

90. Currently, FHA requires mortgagees to have a minimum net 

worth of $250,000 in order to be qualified to underwrite FHA loans. 

Brokers must have a net worth of $63,000. MBA believes that both 

these standards should be increased to make these industries more 

accountable. 

Specifically, we recommend mortgage bankers should have a 

minimum corporate net worth of the greater of $500,000 or 1 percent of FHA loans, up to a maximum of $1.5 million. Mortgage brokers should have a minimum corporate net worth of $150,000, with 

half of 1 percent of their loan volume, up to the minimum of the 

mortgage bankers. 

Finally, Congress needs to address FHA’s loan limits which are 

scheduled to expire January 1st. The markets crave certainty, and 

this is not the time to be reducing loan limits. We support permanently raising FHA loan limits to $625,500, and allowing it to go 

to $729,750 in high-cost areas. 

Now is the time for Congress to improve resources for these 

agencies in order to prevent problems from occurring in the future. 

Thank you. 

Chairman MOORE OF KANSAS. Thank you, Mr. Kittle, for summing up so quickly. 

[The prepared statement of Mr. Kittle can be found on page 58 

of the appendix.] 

Chairman MOORE OF KANSAS. Mr. Savitt, if you would, please. 

STATEMENT OF MARC SAVITT, CRMS, PRESIDENT, NATIONAL 

ASSOCIATION OF MORTGAGE BROKERS 

Mr. SAVITT. Good morning, Mr. Chairman, Ranking Member 

Biggert. As a Main Street mortgage professional for the past 28 

years, I am here to inform you that our fragile housing market is 

once again on the verge of collapse. This time it has nothing to do 

with exotic programs or high interest rates, although it does involve serious acts of misconduct. 

The country’s largest providers of mortgage financing, Fannie 

Mae and Freddie Mac, have seriously strayed from their chartered 

missions, aided by the New York Attorney General, Andrew 

Cuomo. At issue here is the Home Valuation Code of Conduct, 

known as the HVCC. 

11 

In 2007, the Attorney General began an investigation of Washington Mutual and an unregulated appraisal management company 

known as eAppraiseIT. His investigation also warranted subpoenas 

of Fannie and Freddie, where certain information was discovered 

in that investigation which the Attorney General has refused to 

turn over. That investigation is now being concluded. 

As a result of that investigation, we now have the HVCC or the 

Home Valuation Code of Conduct. The same failed and flawed 

model that the Attorney General discovered all of this misconduct 

is now the solution, or the supposed solution, for the problem. And 

what we are seeing here is that the consumer is being seriously 

harmed by this code. 

We estimate that it is costing consumers conservatively $2.8 billion a year in extra charges. This code has created long delays in 

the mortgage financing process, which requires extended lock-in 

fees the consumer pays for. Appraisals have gone from anywhere 

from $150 to $300 more than their normal costs. So what is involved here is serious expenses for the consumer. 

It is also hurting small business. Appraisers are being paid approximately 60 percent of what they were being paid before May 

1st, when this code first went into effect. Mortgage brokers do not 

have the ability to deal with the appraisers that they have been 

dealing with. Years of business relationships have been destroyed. 

And again, these are also causing long delays. 

We have several examples which we would like to submit for the 

record of what this is doing to the American consumer. And we see 

that if this code is not withdrawn shortly, we are going to see even 

more serious consequences. Thank you. 

Chairman MOORE OF KANSAS. Thank you, Mr. Savitt. 

[The prepared statement of Mr. Savitt can be found on page 85 

of the appendix.] 

Chairman MOORE OF KANSAS. Mr. Berenbaum, sir. 

STATEMENT OF DAVID BERENBAUM, EXECUTIVE VICE PRESIDENT, NATIONAL COMMUNITY REINVESTMENT COALITION 

Mr. BERENBAUM. Mr. Chairman, thank you. Ms. Biggert, thank 

you for having us here this morning. 

I would like to start by taking strong exception to Mr. Savitt’s 

remarks with regard to the Home Valuation Code of Conduct. We 

believe a strong HVCC that should be expanded to reach FHA and 

VA loans is critical to protect the consumers’ interests. Quite candidly, lender pressure brought about widescale overvaluation of 

properties. And today the opposite issue of, in fact, lower prices 

through broker price opinions are driving down values and impacting on the tax base around the Nation. 

Second, I would quickly like to make the point that we strongly 

believe there is a need for additional regulation and oversight in 

the FHA program and related government programs, particularly 

with regard to the HECM program and the proprietary products. 

As a national HUD-certified counseling agency, we are seeing 

widescale abuse of seniors at this moment in time who are being 

victimized, as the Comptroller of the Currency noted, by predatory 

practices in that area. 

12 

Third, we are about to release a report where we tested over 200 

providers of foreclosure prevention services. And we completely 

agree with your remarks that in fact it is the Wild West out there. 

What we are seeing is average fees of $2,900 for a service you can 

get for free from your servicer or a HUD-certified counseling agency, coupled with widescale misinformation. 

Last, I would like to speak to some of the issues that we are seeing right now with regard to fraud in the FHA program. We do believe there is a need for greater staffing and oversight within FHA, 

coupled with, in fact, the President’s announcement yesterday that 

there was a need for a consumer financial protection agency. We 

know when there are CRA loans, we know when there is responsible lending. Both consumer protection and profit go hand-in-hand. 

And we hope that working with this committee and each of you in 

the coming year we can realize that environment. Thank you. 

Chairman MOORE OF KANSAS. Thank you, sir. 

[The prepared statement of Mr. Berenbaum can be found on page 

20 of the appendix.] 

Chairman MOORE OF KANSAS. I thank the witnesses for their 

statements. Again, I apologize for this. We are going to move very 

quickly here. I am going to ask unanimous consent from members 

present that each member have 2 minutes to ask a question or ask 

questions. And we will alternate sides. We will get in as many 

questions as we can, and follow up with written questions. 

And each of your testimony will be received, the written statement, in the record, as well as what you have said here today. 

So we are going to start, I would like to ask the first question. 

Mine for 2 minutes is Mr. Donohue. Judging from your statements, 

your testimony, it sounds as if Congress has taken some good steps 

with the Fraud Enforcement and Recovery Act, but unless Congress provides the funding to follow through, some of this is going 

to be for naught. Is that a fair assessment of your testimony, sir? 

Mr. DONOHUE. I do believe that, sir. I think it is very important 

that the funding be addressed in this regard. And, in fact, most recently the Secretary testified to the fact as far as the need of additional IT funding for FHA as well as staffing. They do have a need 

for staffing programs. 

Chairman MOORE OF KANSAS. Mr. Nunnink, do you have any 

comments on that, sir? 

Mr. NUNNINK. I agree with that. 

Chairman MOORE OF KANSAS. All right. Do any other witnesses 

have any other comments besides that they agree funding is necessary for this? Any other comments? 

Mr. PELLEGRINI. Mr. Chairman? 

Chairman MOORE OF KANSAS. Mr. Pellegrini? 

Mr. PELLEGRINI. I would like to point out that—we believe that 

Congress should require borrowers to receive their key closing documents in advance of closing, a consumer protection measure 

which is strongly encouraged and supported by HUD. This would 

give the borrowers the early opportunity, and the closing agents, to 

review those documents. And that would be a strong way to thwart 

fraud. 

Mr. BERENBAUM. Mr. Chairman, I would also like to add we 

would like to see HUD collaborating with the Federal Trade ComVerDate Nov 24 2008 18:26 Oct 08, 2009 Jkt 052402 PO 00000 Frm 00018 Fmt 6633 Sfmt 6633 K:\DOCS\52402.TXT TERRIE
13 

mission in the future on issues that are relevant to marketing of 

products, misrepresentation, and fraud. 

Chairman MOORE OF KANSAS. Mr. Savitt or Mr. Kittle, any comments, sir, either one of you? 

Mr. KITTLE. Well, only to the money issue. The money has been 

authorized. We just want to make sure that it is appropriated. 

And I will give you a specific example. There are HUD systems 

over there right now that are on a system called COBOL, which is 

pre-DOS, which is pre-Windows 2003. And I think there is only— 

and I am not making this up—three or four people left alive who 

can work on the system if it breaks down. It is incredibly antiquated. We can’t talk to them as lenders. And if you want to 

streamline it and save money, we have to appropriate the funds. 

Chairman MOORE OF KANSAS. Thank you to the witnesses, and 

I apologize. My time is up. I am going to yield 2 minutes now to 

the ranking member, Mrs. Biggert. 

Mrs. BIGGERT. Thank you, Mr. Chairman. 

Mr. Pellegrini, you mentioned in your testimony that for borrowers, and to root out fraud more effectively, it would be helpful 

for consumers to have their completed closing documents 24 hours 

in advance of the closing. 

Congresswoman Bean, in one of our markups on mortgages, 

wanted to require that completed documents be presented to the 

consumers 2 days in advance of the closing. That amendment was 

withdrawn because there was some objection, but they are working 

on it. It appears that the 24-hour requirement may be more feasible. Would you just address that a little bit? 

Mr. PELLEGRINI. Well, Congresswoman, the more time that we 

can allow a borrower to examine documents and have them available at the closing, or prior to the closing, would be beneficial. We 

would support any bill that would allow a greater amount of time 

to examine and go over and educate the borrower on the loan process. 

Mrs. BIGGERT. Sometimes I just remember that at the closings 

everything was fine, but there might be something on the title policy that hadn’t been cleared yet, and then that would mean that 

the closing took a little bit longer. Does that still happen a lot? 

Let’s say a fence is over the line and how is that going to be resolved? 

Mr. PELLEGRINI. Of course, those issues always present themselves at the closing table. Often, the closing table is not the culmination of the transaction; sometimes it is merely the beginning 

of the transaction in some instances. But we find those title issues 

to be in place in many situations. But certainly the more preparation that can be done in advance would certainly expedite the closing. 

Mrs. BIGGERT. Thank you. And then I want to go to Mr. 

Donohue. I am concerned about the seniors being victims of fraud. 

How many actual complaints has your office received about the 

HUD programs? Do you have the data or can you get it for us? 

Mr. DONOHUE. I can get the data for you. We have seen an increase. 

Chairman MOORE OF KANSAS. Your microphone, sir? 

14 

Mr. DONOHUE. I don’t have the numbers, Congresswoman, but I 

can certainly get them to you. We have seen an increase in volume 

with regard to cases. I have an active sampling of egregious cases 

to present to you if you would like. 

Mrs. BIGGERT. Good. I would like that very much. 

Chairman MOORE OF KANSAS. Thank you. Your time is up. And 

Mr. Lynch, you are recognized for 2 minutes, sir. 

Mr. LYNCH. Thank you, Mr. Chairman. I appreciate it. I apologize to the witnesses as well. We had no idea this was going to 

happen. 

Mr. Donohue, very quickly. We have concerns about the mutual 

insurance fund, whether we are below 2 percent. And I know FHA 

is only required to report once a year. I am very nervous about 

that, given that we were down 40 percent the last time we checked. 

Do you have any information for the committee with respect to 

whether or not we are below that 2 percent minimum? 

Mr. DONOHUE. Sir, they are currently doing—first of all, we have 

met with your office as well. We support your legislation. 

Mr. LYNCH. Right. You are very good on that. I appreciate it. 

Mr. DONOHUE. I certainly support the idea of doing the actuarial 

study twice a year, as you have recommended. But the thing as far 

as the numbers are concerned, we are watching this closely. We 

have our own independent auditors that are watching the actual 

study itself. The one problem that is faced with, as you might be 

aware, is the recovery rates on foreclosure properties. They had estimated that last year at 60 percent. It is down more like 40 percent. 

Mr. LYNCH. Right. 

Mr. DONOHUE. So the question has come back down as to what 

point it is. The Secretary made some comments last week, but we 

will watch this very closely. 

Mr. LYNCH. All right. I am running out of time here, the little 

that I have. 

Now, you know, you were doing 3 percent of the market, now 

FHA is doing 30 percent of the market, and the market is tanking. 

I can’t imagine how we are going to end up with a result where 

we are above our 2 percent. I think we are going to have problems. 

I would like to have an opportunity, if we can’t have a hearing— 

and I know that the chairman is jammed because he has a certain 

set of schedules for hearings going into August, ending in August. 

Would you be willing to meet with me and my office? I would like 

to meet with FHA and also Ginnie Mae. I have problems over there 

as well. And it is just a shame that this has happened on this day, 

but some of this stuff is out of our control. But we are going to 

have to take a real hard look at this. 

Mr. DONOHUE. I am more than happy and more than willing, sir, 

to sit down with you and discuss this in detail. 

Mr. LYNCH. Thank you. I yield back. 

Chairman MOORE OF KANSAS. Thank you, Mr. Lynch. 

And I want to ask another question. We are going to have another round. I think we have time for 2 minutes each. 

Mr. Nunnink, one issue that concerns me is appraisal fraud and 

the role of appraisals in our mortgage systems. I think this is an 

15 

important issue. The Inspector General suggested bringing back 

the FHA Appraiser Fee Panel. 

Can you talk about appraisal fraud? How much of an issue is it 

in our current system? And what can be done to correct it? In 

about 1 minute, 44 seconds. 

Mr. NUNNINK. Yes. Very simply stated, that FIRREA has effectively dealt with eliminating appraisal fraud, and it was passed in 

1989. It is entirely possible to have separation at a bank between 

those ordering the appraisal and those originating mortgages. So I 

don’t think a panel like FHA is necessary. I think less government 

is better than more government. 

And so my conclusion is that the existing system, if you follow 

Home Valuation Code of Conduct, will suffice. 

Chairman MOORE OF KANSAS. Do any other witnesses have comments on this? 

Mr. BERENBAUM. I would like to comment on that, Mr. Chairman. 

Chairman MOORE OF KANSAS. Yes, sir, Mr. Berenbaum. 

Mr. BERENBAUM. I believe actually the valuation issue remains 

one of the outstanding issues that has not been addressed by either 

statute or regulatory reform discussions at this point. The Appraisal Foundation and other key players in this industry have not 

really done enough to ensure accuracy in valuation. We have been 

commenting on this issue for several years now. And again here we 

are today with broker price opinions being used that are depressing 

values across the country, and they are conflicted. So this is an 

issue that needs more attention. 

Chairman MOORE OF KANSAS. Do any other witnesses have—we 

have 20 seconds? Yes, sir, Mr. Savitt? 

Mr. SAVITT. Mr. Chairman, what we are looking at here with appraisals, we are looking for appraisal independence, and we don’t 

have that with the Home Valuation Code of Conduct. The results 

of the Attorney General’s Office was from an investigation of a federally chartered bank and an unregulated appraisal management 

company. That is the model they are using today. As a matter of 

fact, the banks and some of the lenders actually have joint ventures, where they own up to 20 percent of those appraisal management companies. It is the same failed, flawed model that created 

the investigation. So with that, how do we have appraisal independence? We don’t. 

Chairman MOORE OF KANSAS. Thank you. Again, I apologize. 

Ranking Member Biggert is recognized for 2 minutes. 

Mrs. BIGGERT. Thank you. Mr. Savitt, could you tell me how the 

implementation of the Home Valuation Code of Conduct has impacted your members and consumers? What type of cost increases 

have been to consumers as a result of the implementation? And 

how is the average consumer affected by that? 

Mr. SAVITT. The average consumer is affected by it costing them 

substantially more money. We used data from HMDA and also 

from Wholesale Access, and we came up with a number of $2.8 billion. And that is a very conservative number, because we knew 

that number might be attacked, so we wanted to go on the low 

side. That is additional lock-in fees because the appraisals are taking anywhere from 35 to 40 days longer than they used to. That 

16 

results in longer lock-in fees which the consumer pays, usually a 

minimum of a quarter percent. And then appraisals that used to 

cost anywhere between $350 and $400 are now costing anywhere 

between $500 and $750. My own office, we used to pay $350. We 

are now paying $750 for appraisals. And this works, as I said, out 

to $2.8 billion. This is hurting mortgage brokers, it is hurting—by 

losing deals over this. It is destroying relationships, it is hurting 

the appraisers, who are being paid 60 percent less. 

Mrs. BIGGERT. Thanks. I have one more question I want to get 

in to Mr. Kittle. FHA may require taxpayer funding next year for 

the first time in its history. Is there anything that we can do today 

proactively to avert large losses in the years to come? 

Mr. KITTLE. Well, you can appropriate the funds to make them— 

technologically bring them into the 20th Century. That is the first 

thing you could do. And to go back to Mr. Lynch’s comment just 

a minute ago, or his issue, if they have the right computer systems 

and the right reporting systems, he can get the reports he needs 

not once a year or twice, but maybe monthly. We need to just bring 

them up technologically. It will help stop fraud. I mean fraud is 

rampant, but— 

Mrs. BIGGERT. Every year they say they are going to do this, and 

it never comes to fruition. Thanks. 

Mr. KITTLE. We need to appropriate the money. 

Chairman MOORE OF KANSAS. Again, my thanks to the panel 

members and my thanks to the witnesses who have testified here 

today. I look forward to working with our witnesses, and my Republican and Democratic colleagues, to ensure our constituents are 

protected to the greatest extent possible. 

The Chair notes that some members may have additional questions, and other members who are not present may have additional 

questions for this panel which they may wish to submit in writing. 

Without objection, the hearing record will remain open for 30 

days for members to submit written questions to these witnesses 

and to place their responses in the record. 

Again I apologize for this. I thank the witnesses for traveling 

here and for your testimony. This hearing is adjourned. 

[Whereupon, at 10:47 a.m., the subcommittee was adjourned.] 

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A P P E N D I X 

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