Specific Requirements of FHA and USDA

Specific Requirements of FHA and USDA

Specific Requirements of FHA and USDA When Using the Chenoa Fund

Understanding the specific requirements of FHA and USDA loans is essential when pairing them with the Chenoa Fund down payment assistance program. Each loan type comes with its own guidelines for credit, income, property eligibility, and occupancy, which must be met in addition to Chenoa Fund requirements. By knowing how FHA and USDA rules align with the Chenoa Fund, homebuyers can better prepare for approval and select the financing option that best fits their situation.

The Chenoa Fund, administered by CBC Mortgage Agency (CBCMA), operates as a correspondent lender program designed to expand access to homeownership. While best known for its down payment assistance (DPA), the program’s utility is defined by how it interacts with standard government-insured mortgages. Specifically, the Chenoa Fund offers distinct products for Federal Housing Administration (FHA) loans and U.S. Department of Agriculture (USDA) loans.
The requirements for these two loan types differ significantly under the Chenoa Fund umbrella. While the FHA program is structured around secondary financing to cover down payments, the USDA offering is a standalone first mortgage product that prohibits down payment assistance. Understanding the specific underwriting guidelines, property eligibility, and borrower restrictions for each track is essential for navigating the program.

Part 1: Chenoa Fund Requirements for FHA Loans

The core of the Chenoa Fund is its FHA-paired program. In this scenario, CBCMA purchases the FHA-insured first mortgage and provides a second mortgage (either repayable or forgivable) to satisfy the borrower’s Minimum Required Investment (MRI).

1. First Mortgage Specifications
To be eligible for Chenoa Fund assistance, the underlying first mortgage must adhere to strict parameters:

  • Loan Term and Type: The first mortgage must be a fixed-rate loan with a term of 25 or 30 years. It must be fully amortizing; adjustable-rate mortgages (ARMs) and interest-only options are not permitted.
  • Product Type: The loan must be underwritten as an FHA 203(b) for 1–2 unit properties. This includes standard single-family residences, planned unit developments (PUDs), townhomes, condominiums, and eligible manufactured homes,.
  • High Balance Loans: The program permits “High Balance” FHA loans (loans exceeding the standard conforming limit but within high-cost area limits) for most product variations. However, High Balance loans are explicitly prohibited when using the 5% forgivable down payment assistance option,.

2. Down Payment Assistance Structure
The specific requirements for the second mortgage depend on whether the borrower chooses the repayable or forgivable option.

  • Amounts: Borrowers may receive 3.5% or 5% of the lower of the purchase price or appraised value,.
  • Forgivable Requirements: For the forgivable product (0% interest, no monthly payments), the loan term is 30 years. Forgiveness occurs only after the borrower makes 36 consecutive, on-time payments on the FHA first mortgage. If a borrower makes a payment that is 30 days or more delinquent, the 36-month forgiveness counter resets, requiring the borrower to start a new streak of on-time payments to re-qualify,.
  • Repayable Requirements: The repayable product requires monthly payments over a 10-year term. The interest rate for this second lien is set at 1% higher than the interest rate on the first FHA mortgage.

3. Underwriting Overlays for FHA
CBCMA applies specific “overlays”—requirements that go beyond standard FHA guidelines—to manage risk.

  • Credit Score: The minimum qualifying credit score is 600. All borrowers on the transaction must have at least one valid credit score; borrowers with non-traditional credit only are generally not eligible.
  • Debt-to-Income (DTI): For borrowers with credit scores of 600 and above, the DTI ratio is determined by the findings of the Automated Underwriting System (AUS). CBCMA accepts the DTI approved by DU or LP without a hard cap, provided the loan receives an “Approve/Eligible” or “Accept” recommendation.
  • Manual Underwriting: As of October 16, 2023, manual underwriting for FHA loans is suspended. All loans must receive an automated approval to be eligible for purchase.
  • Income Limits: A distinguishing feature of the Chenoa Fund’s current FHA guidelines is the absence of income caps. For the standard offerings, there are “no income limitations at this time,” and Area Median Income (AMI) calculations are not required.

4. Property and Occupancy

  • Occupancy: At least one borrower must occupy the property as their primary residence. Investment properties are ineligible.
  • Non-Occupant Co-Borrowers: Non-occupant co-borrowers are allowed per FHA guidelines (typically restricted to family members). Importantly, if a non-occupant co-borrower is present, their income is generally included for qualifying purposes, but AMI thresholds (if applicable for specific sub-products) usually focus on the occupying borrower’s income.
  • Manufactured Housing: Manufactured homes are eligible but subject to rigorous standards. They must be double-wide or larger (single-wide units are ineligible), built on or after June 15, 1976, and permanently affixed to the land with title purged/surrendered. A structural engineering report is mandatory,,.
Chenoa Fund Requirements for USDA Loans​

Part 2: Chenoa Fund Requirements for USDA Loans

CBCMA offers a USDA Rural Development (RD) 30-year loan program. It is critical to note that this is a standalone first mortgage product.

1. No Down Payment Assistance
The most specific requirement regarding the Chenoa Fund USDA program is a restriction: Secondary financing (down payment assistance) is not allowed. Borrowers utilizing the Chenoa Fund channel for a USDA loan cannot pair it with the 3.5% or 5% DPA second mortgages available for FHA loans. The USDA loan itself is designed as a zero-down program, allowing borrowers to finance 100% of the home’s value.

2. Geographic and Borrower Eligibility

  • Location: The property must be located in an eligible rural area as defined by the USDA. Lenders must verify eligibility through the USDA property address search tool.
  • Income Limits: Unlike the FHA products which may have no income caps, the USDA program strictly enforces income limits. Borrowers must meet the USDA’s definition of low-to-moderate income, which typically caps eligibility at 115% of the area median income. This limit applies to the adjusted annual household income of all adult occupants, not just the borrowers on the loan,,.
  • Occupancy: The applicant must occupy the property as their primary residence. The program is not available for income-producing properties or farms.

3. Underwriting Standards
CBCMA underwrites USDA loans based on the USDA 3555-1 Technical Handbook.

  • Ratios: The standard qualifying ratios are 29% for the principal, interest, taxes, and insurance (PITI) and 41% for the total debt-to-income (TD) ratio.
  • Credit Analysis: Borrowers must not qualify for “Traditional Conventional Credit” (meaning they must demonstrate a lack of 20% down payment funds to qualify for the USDA guarantee).
  • CAIVRS: A clear CAIVRS response (Result “A”) is required. Borrowers with delinquent federal debt are ineligible.
  • Adverse Credit: Significant derogatory events like foreclosure or Chapter 7 bankruptcy generally require a 36-month waiting period before eligibility is restored,.

Part 3: Shared Operational Requirements and Documentation

Certain requirements apply broadly across the Chenoa Fund platform or involve specific logistical steps for lenders.

1. Homeownership Education
Education is a mandatory requirement for borrowers with lower credit profiles, regardless of the loan type.
• Credit Scores 600–619: Borrowers must complete a counseling course specifically through Money Management International (MMI). CBCMA covers the cost of this course.
• Credit Scores 620–639: Borrowers may use any HUD-approved counseling course, including Framework or Homeview. If they choose MMI, CBCMA pays the fee.
• Credit Scores 640+: Borrowers in this range are exempt from the education requirement.

2. Documentation and Verifications
• Work History: All loan applications must document a two-year employment history. Gaps in employment may require a Letter of Explanation.
• Self-Employment: For self-employed borrowers, the business must be verified as open and operating within 30 days of the Note date. Acceptable verification includes current invoices, receipts, or a lender certification via phone call.
• Tax Transcripts: IRS tax transcripts are required for self-employed borrowers or any borrower where tax returns are used to qualify. They are generally not required for W-2 only income unless quality control concerns arise.
• Source of Funds: For FHA loans using DPA, the source of funds on the Closing Disclosure (CD) must be identified as “CBC Mortgage Agency” (not “Chenoa Fund”). The closing costs for the secondary financing must be properly disclosed,.

3. Fees and Points
• Admin Fee: A $399 administration fee is charged to the correspondent lender. This fee cannot be passed to the borrower in Section B or C of the Closing Disclosure but may be included in Section A (Origination Charges).
• Points Cap: CBCMA will not purchase loans that exceed the Qualified Mortgage (QM) 3% points and fees test. Bona fide discount points are allowed but must be documented with a rate sheet from the day of the lock to distinguish them from non-bona fide points,.
• Origination Fees: On the first mortgage, lenders generally may charge up to 1.5% origination fee. On the second mortgage (DPA), lenders are prohibited from charging “lender fees.” Only permissible fees like prepaid interest and recording fees are allowed on the second lien,.

4. Subordination and Refinancing
The Chenoa Fund has strict rules regarding the subordination of the second mortgage (DPA) if the borrower decides to refinance the first mortgage.
• 36-Month Rule: Subordination is generally not allowed during the first 36 months of the loan. If a borrower refinances the first mortgage within this window, the second mortgage must be paid in full.
• Forgivable Loan Clawback: If a borrower with a forgivable second mortgage refinances the first mortgage, the loan permanently loses its forgivable status. It remains a 0% interest loan but must be repaid in full upon the next refinance, sale, or maturity.
• Exceptions: Subordination may be considered after 36 months for repayable loans if the borrower has a perfect payment history, subject to a processing fee.

The Chenoa Fund’s requirements create two distinct pathways. For FHA borrowers, the program offers a high-leverage solution allowing for 100% financing (via DPA), accommodating credit scores down to 600, and permitting high balance loans, provided the borrower accepts the 36-month forgiveness timeline or the 10-year repayment schedule. For USDA borrowers, the program acts purely as a secondary market outlet for standard zero-down rural loans, enforcing strict income caps and prohibiting further down payment assistance. In both cases, adherence to the specific overlays regarding manufactured housing, self-employment verification, and fee caps is mandatory for a successful transaction.

FAQ's

For FHA loans, closing costs cannot be rolled into the mortgage balance; however, the 5% Chenoa Fund assistance option often provides enough funds to cover the 3.5% down payment plus some closing costs. For USDA loans, there is a unique flexibility: if the appraised value of the home exceeds the purchase price, borrowers may roll the closing costs and prepaid items into the loan amount, up to the appraised value. For example, if a home is purchased for $250,000 but appraises for $255,000, the borrower can finance the $5,000 difference to pay for closing costs, effectively reducing their out-of-pocket expense.

Both the FHA and USDA programs under the Chenoa Fund are strictly for owner-occupied primary residences. Investment properties, vacation homes, and second homes are not eligible. For FHA loans, at least one borrower must occupy the property within 60 days of closing and continue to occupy it for at least one year. For USDA loans, the applicant is similarly required to occupy the property as their primary residence. While non-occupant co-borrowers are permitted for FHA loans (typically restricted to family members), the primary borrower must still live in the home. Occupancy is verified through loan documents and intent-to-proceed declarations.

Manufactured homes are eligible for the Chenoa Fund FHA-paired program but are subject to strict overlays. The home must be a multi-wide unit (double-wide or larger); single-wide units are ineligible. It must be permanently affixed to the land, built on or after June 15, 1976, and bear the HUD Certification Label. A structural engineering report is mandatory. For the USDA program administered by CBC Mortgage Agency, manufactured housing is generally subject to the specific guidelines within the USDA Technical Handbook, but lenders must ensure the property meets all agency-specific foundation and titling requirements, including the surrender of the vehicle title to classify the home as real property.

The FHA first mortgage paired with Chenoa Fund assistance must adhere to specific loan terms to be eligible for purchase. The loan must be a fixed-rate mortgage with a term of either 30 years or 25 years. Adjustable-rate mortgages (ARMs) and interest-only loans are strictly prohibited. Additionally, the loan must be fully amortizing. These strict parameters ensure the stability of the primary financing. While the first mortgage follows standard FHA 203(b) guidelines, these overlay requirements regarding the loan term and type are mandatory for utilizing the down payment assistance program.

Yes, the USDA program includes a specific asset test to ensure the program serves those who truly need government-backed financing. To qualify, an applicant must not meet the definition of “Traditional Conventional Credit.” This means the applicant cannot have sufficient non-retirement liquid assets to make a 20% down payment on the home. If a borrower has enough personal liquid funds to put 20% down and pay for closing costs while still qualifying for a conventional mortgage, they are ineligible for the USDA guarantee. This requirement ensures the zero-down benefit is reserved for low-to-moderate-income borrowers with limited savings.

USDA loans have unique property eligibility requirements compared to FHA loans. First, the property must be located in a designated eligible rural area as defined by the USDA; there are no exceptions to this geographic rule. Second, the property cannot include buildings or land principally used for income-producing purposes. This means properties with commercial greenhouses, livestock facilities, or barns used for commercial farming are ineligible. While a minimal home-based business or a small garden is acceptable, the site generally cannot be used for agricultural or commercial enterprise, and the value of the site must not exceed 30% of the total property value.

As of October 16, 2023, manual underwriting for FHA loans has been suspended by CBC Mortgage Agency. To be eligible for purchase, all FHA loans must receive an “Approve/Eligible” or “Accept” recommendation from an Automated Underwriting System (AUS), such as Desktop Underwriter (DU) or Loan Prospector (LP). Previously, loans with “Refer” findings could be manually underwritten if they met strict compensating factor requirements, but this is no longer an option. Consequently, borrowers must have a credit profile strong enough to secure an automated approval to qualify for the Chenoa Fund FHA program.

The income requirements differ significantly between the two programs. For the standard Chenoa Fund FHA-paired down payment assistance products, there are currently no borrower income limits, nor are there requirements to calculate Area Median Income (AMI) for eligibility. This offers flexibility for higher-income borrowers lacking liquid savings. In contrast, the USDA program enforces strict income caps. To qualify for the USDA loan, the applicant’s adjusted annual household income generally cannot exceed 115% of the Area Median Income. Furthermore, USDA income calculations must include the income of all adult household members, not just the borrowers on the loan.

Yes, “High Balance” FHA loans—those that exceed standard conforming loan limits but remain within the ceiling for high-cost areas—are eligible, but specific restrictions apply based on the type of assistance chosen. You may utilize High Balance loans if you select the Repayable Second Mortgage at either the 3.5% or 5% assistance level. However, if you prefer the Forgivable Second Mortgage option, it is only permitted for High Balance loans receiving 3.5% assistance. The 5% Forgivable down payment assistance option is strictly prohibited for High Balance FHA loan transactions under current program guidelines.

No, you cannot combine Chenoa Fund down payment assistance (secondary financing) with a USDA loan. While CBC Mortgage Agency offers a USDA Rural Development 30-year loan program, it functions as a standalone first mortgage product. The USDA loan program is inherently designed as a zero-down payment option, allowing eligible borrowers to finance 100% of the home’s value without needing additional assistance for a down payment. Consequently, the 3.5% or 5% second mortgage assistance products provided by the Chenoa Fund are exclusively paired with FHA-insured mortgages and are not available for use with the USDA loan offering.

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