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Input: The Rainy Day Foundation advertises that it can help lenders remain in the FHA's good graces. For a fee of about $600 per borrower  paid by lenders  home builders and real estate firms to cover the cost of making mortgage payments for distressed borrowers  the group promises to limit defaults during the two years after a loan is made  the period watched most closely by the FHA. Rick Del Sontro  chief executive of the Rainy Day Foundation  said in an interview that his group provides an important service to borrowers and lenders.
 Del Sontro said in the interview that his nonprofit benefits borrowers  lenders and the FHA by helping people deal with unexpected financial setbacks.
 "The first financial challenge that hits (borrowers) can be potentially disastrous " Del Sontro said. "And that's why we created the Rainy Day program."
 Del Sontro did not respond to subsequent voice-mail messages requesting comment on Rainy Day's marketing techniques and on the Justice Department's allegations about the group. In response to one of three text messages sent to him by a reporter  he wrote  "I am not familiar with the allegations so I can't really comment on them."
 Del Sontro said in an interview that from the beginning he regarded Rainy Day's services primarily as a way for lenders to reduce defaults  particularly during the first two years after a loan was made  the critical period tracked by HUD in its database of lender performance. Del Sontro said his group's services were also valuable to lenders for another reason: because loans often were sold to investors with the promise of a reimbursement in the event of an early default.
 "We thought of the program as a risk mitigation tool for lenders " Del Sontro said. Before launching his nonprofits  Del Sontro worked as senior vice president of franchise and sales development for Cendant Real Estate  a unit of the New York-based conglomerate Cendant Corp. That company split up after disclosing accounting irregularities in 1998.

Straining the FHA's Umbrella