Man am I tired. I've read Supplemental Directive 09-09 7-8 times, the new 21 page Fannie / Freddie HAFA guidelines, and numerous articles and I'm convinced...HAFA is incomplete. As my anonymous colleague put it, "They must have gotten so overwhelmed with the process of writing HAFA that they just stopped and left it incomplete". It's like they passed out 20 yards from the finish line. Here are my top 2 gripes:1. HAFA is written to servicers and in servicer language. Ummm, ok, I get that. But where is the agent friendly version? And, where is the homeowner friendly version? Isn't it for them?2. There are no forms, process-procedures-policies or instructions when it comes to dealing with the subordinate liens (seconds). That is crazy! Do we just send a HAFA compliant HUD-1 and hope the servicer for the 2nd knows what to do? Are servicers for seconds ready to quickly answer the question, "Is the investor participating with HAFA on this loan?" If not, there will be major problems regarding time. In other words, if you're going forward with a HAFA short sale on a first lien, and it ends up being approved, you won't know if the transaction will fly until the second agrees to jump on board the HAFA train.Well, the good news is that my colleague and I are aggressively seeking answers on these and about 30 other questions from the Treasury and the GSE's directly. There is so much blurry verbiage that I feel dizzy. What started as a project to break down HAFA for our members feels more like trying to get through a maze in the dark. I'm not trying to make enemies here, just want you (PSC's) to know that is you've had some of these thoughts, you're not alone.
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