BlackLeafwatch the watchmen
FHA Mortgage Insurance

FHA's reserves are the strongest on record. Its debt collector isn't working.

Summary

The federal mortgage insurer backing $1.65 trillion in home loans holds five times the capital Congress requires. But its own inspector general sampled 81 borrower files and found servicing or collection errors in 74 of them — 91 percent.

By Nero · July 9, 2026

The Federal Housing Administration insures mortgages so lenders will approve buyers who couldn't otherwise qualify — mostly first-time and lower-income homebuyers. As of September 30, 2025, carried active insurance on more than 8.1 million forward mortgages worth over $1.65 trillion in unpaid principal balance, and the insurance fund behind that book holds more capital, relative to its size, than at any point since Congress started requiring a minimum reserve. By that measure the program is a success story. Underneath it, a separate report tells a different story about what happens once a borrower actually falls behind.

Active FHA-insured mortgages
8.1M
worth $1.65T, FY2025
MMI Fund capital ratio
11.47%
vs. 2.00% statutory floor
Sampled loan files mishandled
91%
74 of 81 files, OIG audit

The Fund is the strongest it has been on record

's Mutual Mortgage Insurance (MMI) Fund is the reserve that absorbs losses when insured borrowers default. Congress requires it to hold capital worth at least 2.00 percent of the loans it insures. As of September 30, 2025, the Fund's Capital Ratio stood at 11.47 percent — more than five times the statutory minimum, and tied with the prior year for the highest level on record since the ratio became a legal requirement. MMI Fund capital reached $188.87 billion, up $16.11 billion in a single year, even as the book of insured loans grew to $1.65 trillion.

FHA MMI Fund Capital Ratio, FY2019–FY2025
Percent of Insurance in Force; statutory minimum is 2.00%
FY2019
4.8%
FY2020
6.1%
FY2021
8%
FY2022
11.1%
FY2023
10.5%
FY2024
11.5%
FY2025
11.5%
Source: HUD/FHA, Annual Report to Congress on the Financial Status of the MMI Fund, FY2025 (issued December 2025)
View data as table
MMI Fund Capital Ratio by fiscal year
FY20194.84%
FY20206.10%
FY20218.03%
FY202211.11%
FY202310.51%
FY202411.47%
FY202511.47%statutory minimum: 2.00%

That climb — from 4.84 percent in FY2019 to 11.47 percent today — is the product of a decade of premium collections outrunning claims. It is also, by itself, a balance-sheet number. It says nothing about whether the office that has to act on any individual borrower's file is actually doing its job.

The office that acts on the file is not

When an borrower falls behind, one of the tools uses to keep them in their home is a "partial claim" — advances funds on the borrower's behalf to bring the loan current, and the borrower signs a second, interest-free note that isn't due until the first mortgage is paid off, refinanced, or otherwise ends. Servicing and collecting on those notes is handled by 's National Servicing Center (NSC) through a private contractor. Between fiscal years 2021 and 2024, more than 340,000 of these partial claims came due as the underlying mortgages terminated.

The HUD Office of Inspector General audited that process and pulled a statistical sample of 81 loan files. Seventy-four of the 81 — 91 percent — had at least one servicing or collection error: missing demand letters, unreclaimed lender incentive fees, incomplete servicing files, late payoff processing, unfiled bankruptcy claims, or delayed lien releases.

What went wrong in FHA's own audit sample
Share of 81 sampled partial-claim loan files with each discrepancy type (a file can have more than one), FY2021–FY2024 terminations
Servicing file incomplete or inaccurate
88.9%
Lien release recorded late
45.7%
Payoff check deposited late
17.3%
Demand letter not sent, or sent late
11.1%
Lender incentive fee not reclaimed
11.1%
Bankruptcy proof of claim filed late
3.7%
Source: HUD Office of Inspector General, Audit Report 2026-KC-0005 (issued June 25, 2026)
View data as table
Discrepancy rate by category
Servicing file incomplete or inaccurate88.9%72 of 81 files
Lien release recorded late45.7%37 of 81 files
Payoff check deposited late17.3%14 of 81 files
Demand letter not sent, or sent late11.1%9 of 81 files
Lender incentive fee not reclaimed11.1%9 of 81 files
Bankruptcy proof of claim filed late3.7%3 of 81 files

The two most common failures carry direct consequences for borrowers, not just 's books. In 37 of 81 files (45.7 percent), the servicing contractor failed to record a lien release on time — delays ran from 11 to 594 business days — which the report notes "may end up costing the borrower the sale or refinance opportunity" on their own home. And in 72 of 81 files (88.9 percent), servicing records were incomplete or inaccurate, which the inspector general found delays debt collection "potentially rendering it uncollectable if enough time passes," a direct risk to the insurance fund the same report celebrates elsewhere.

Auditors attributed the failures to a post-pandemic surge in partial-claim volume, reliance on manual processing, and a servicing contract that — after four years in force — still lacked defined performance metrics for the contractor to be held to. 's own contract monitors reviewed the contractor quarterly between October 2021 and February 2025 and never once flagged a discrepancy.

The takeaway

  • Two separate systems, two separate report cards. The MMI Fund's solvency and the National Servicing Center's execution are graded by different offices on different criteria — one can be excellent while the other fails, and in FY2025–2026, that is exactly what happened.
  • The reserve is not the risk. At 11.47 percent, 's capital cushion is not what borrowers or taxpayers need to worry about right now.
  • The paperwork is the risk. Nine in ten sampled files were mishandled in a program whose entire purpose is helping distressed borrowers avoid foreclosure — and the errors compound the longer they go uncorrected, by 's own account.

Figures cover the forward (non-reverse) mortgage program only, as reported for fiscal year 2025 and the 's FY2021–2024 audit window; HECM reverse-mortgage totals are cited separately and not included in the headline figures above.

Sources

  • /Annual Report to Congress Regarding the Financial Status of the Mutual Mortgage Insurance Fund, Fiscal Year 2025 (issued December 2025) — Insurance in Force, MMI Fund Capital, and Capital Ratio figures, FY2019–FY2025, and the count of active insured mortgages. hud.gov
  • Office of Inspector General — Did Not Correctly Service all Due and Payable Partial Claims, Audit Report 2026-KC-0005 (issued June 25, 2026) — the 81-file statistical sample, the 74-file (91%) error rate, and the discrepancy-type breakdown. hudoig.gov
Weekly digest: the most-read systems, in brief. Mondays.

Comments

Always open. Logged-in readers can annotate paragraphs in place.

Loading comments…
or log in to comment under your account