The Collingwood Group Official Statement on FHA Loan-level Certification

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Business Advisory firm commends FHA's effort

Washington, DC based business advisory firm, The Collingwood Group, applauds the FHA for providing true leadership and courage in publishing yet another version of its loan-level certification for public comment. FHA is striving to achieve competing objectives - establishing a narrowly defined and crystal clear set of lender obligations and liability while also setting forth permissive terms that will preserve the discretion of enforcement authorities to pursue and take action. Whether the proposed language accomplishes this set of objectives and whether it is possible to use the certification as the vehicle for doing so are open questions.

However, the fact that FHA continues to put forward ideas and options is a testament to the agency's willingness and commitment to serve as the catalyst for the kind of cooperation that is required for true market recovery. The proposed changes to the certification are an unambiguous indication of FHA's interest in establishing a middle ground position and, as such, are worthy of recognition.

About The Collingwood Group
The Collingwood Group is a Washington, DC-based business advisory firm focused on growing clients’ businesses, promoting revenue growth and increasing investment returns while mitigating risks. Our expertise spans all aspects of Agency, non-Agency and FHA/VA housing financing programs; Ginnie Mae securitization activities; domestic and international secondary market activities and issues; primary and special servicing; full asset lifecycle vendor and talent management; and all elements of portfolio due diligence, acquisition, property management and asset disposition.

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Margaret Mooney
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The Collingwood Group
since: 11/2009
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