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494 Dissenting Statement

Figure 4. Estimated Percentage of Home Purchase Volume with an LTV or CLTV >=97%
(Includes FHA and Conventional Loans*)
and Combined Foreclosure Start Rate for Conventional and Government Loans

*Fannie‘s percentage of home purchase loans with an LTV or CLTV >=97% used as the proxy for
conventional loans.
Sources: FHA 2009 Actuarial Study, and HUD”s Offi ce of Policy Development and Research - Profi les
of GSE Mortgage Purchases in 1999 and 2000, in 2001-2004, and in 2005-2007, and Fannie’s 2007 10-K.
Compiled by Edward Pinto.
Th e close relationship between low downpayments and delinquencies and
defaults on mortgages is shown in Figure 5, which compares the increase in FHA 97
percent (or greater) CLTV or LTV mortgages to the increase in the foreclosure start
rate on all loans published by the Mortgage Bankers Association.
Figure 5. Relationship between low downpayments and delinquencies or defaults on mortgages

’
Sources: MBA National Delinquency Survey, FHA 2009 Actuarial Study, and HUDs Offi ce of Policy
Development and Research - Profi les of GSE Mortgage Purchases in 1999 and 2000, in 2001-2004, and
in 2005-2007, SMR’s “Piggyback Mortgage Lending,” and Fannie’s 2007 10-K. Fannie is used as the
proxy on the conventional market. Compiled by Edward Pinto.