``HARP allows borrowers with less than 20 percent home equity to refinance without obtaining mortgage insurance or by rolling over existing policies, a primary difference with the companies' standard streamline programs.

The damage to investors from a resumption of traditional programs would be mitigated by higher benchmark interest rates or further increases in the fees Fannie Mae and Freddie Mac charge for guaranteeing mortgage bonds, which usually increase new-loan rates and reduce refinancing incentives, they wrote.''

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