The government s refinancing and loan modification program is on track to offer assistance to up to three to four million homeowners over the next three years, according to a Treasury Department report released Tuesday.

The report offered the first glimpse of how the Making Home Affordable Program has made headway in helping troubled homeowners over the last few months.

More than 235,000 loan modifications and claims are now underway. The Obama administration has said the program aims to help 500,000 borrowers by Nov. 1.

Here s what these numbers don't say:

1. Servicers modified more loans on a voluntary basis before the government budged in.

Mortgage servicers had been modifying loans on a voluntary basis before the government s Making Home Affordable program, or HAMP, kicked in. (Joining the program was voluntary, but according to the Treasury, servicers covering 85% of loans now participate.)

In the first quarter of this year, servicers initiated 370,000 voluntary modifications. The Treasury is reporting the start of 235,247 trial modifications for May, June and July. In effect, that s a reduction in the number of modifications, says Alan White, an associate professor of law at Valparaiso University, who has studied servicers' voluntary modification efforts. The administration hasn t dramatically increased the number of homeowners who ve been helped, he says.

2. The success rate is still questionable.

The problem with assessing loan modifications before the government s program kicked in was that more than half of all modified loans were back in default just six months after modification, says David Sisko, the head of default management services for Deloitte & Touche LLP. HAMP modifications, arguably, will have a better success rate because they are designed to lower homeowners monthly payments to a level they can afford. But another big problem with the program remains, White says: HAMP does nothing to address the fact that many homeowners owe more on their mortgages than their homes are worth. If the program were modified to include principal reductions for borrowers who are underwater, that would increase the success rate, White says.

3. The loan modification numbers may need to be revised soon.

To register a trial HAMP modification, servicers are permitted to collect a borrower s information by phone only and collect the necessary paperwork later. So many of the 235,247 trial modifications were based on verbal statements from borrowers, says Paul Koches, executive vice president of mortgage servicer Ocwen. Should the information provided by the homeowner turn out to be inaccurate or the paperwork incomplete, the modifications will have to be disqualified or started again. To avoid this risk, which is not insubstantial, Ocwen begins a loan modification only after receiving all necessary paperwork from the borrower. The result: This has kept the rate at which Ocwen starts modifications fairly low, at 5%. However, it is also possible that the application process is elevating the rate for servicers who aren t taking Ocwen s approach.