No,
If the original loan is $300,000 and current appraised value is $200,000, the original lender has to write down $100,000 and let the borrower to apply for the new FHA Loan. The original lender at this stage is done and has nothing else to do with this homeowner or the new refinance . The HUD is going to issue a fresh FHA loan in the amount of $180,000 and let the homeowner to start paying monthly payments of that new loan. So, if the market value of home is $200,000 and the only loan on it which is an FHA fixed rate loan is $180,000, the homeowner is going to have $20,000 equity on that home immediately. It is not too bad for the homeowner who was short on his equity before this loan and is going to be ahead by FHA refinancing.
What am I not seeing: Original loan $300,000. Write down -$100,000. New loan is 90% of the new balance...$180,000. Who comes up with the $20,000 difference? There is not $20,000 extra, it is SHORT $20,000.