Probably the biggest hole in HASP is that it won’t help many people where house prices have fallen most: California, South Florida, Las Vegas and Phoenix. A lot of these people won’t be eligible for refinancing because they owe much more than their houses are worth.
Another gap in the plan: It provides a path to refinancing for people whose loans were securitized by Fannie Mae or Freddie Mac. Millions of homeowners have mortgages that were securitized, but not by Fannie Mae or Freddie Mac. They might find it difficult to refinance, whereas their neighbors who got similar loans securitized by Fannie or Freddie might have an easier time qualifying for refinancing. Most borrowers won’t know if they have a Fannie or Freddie loan until they ask the servicer.
That last requirement effectively imposes a limit on loan amounts. Few mortgages for more than $417,000 will qualify for refinances because that is the conforming limit.