Advocacy and Policy Initiatives

Advocacy

CHLA Asks Top Federal Officials for Small IMB Lender Protections to Sell Loans in Wake of Forbearance

CHLA today sent a joint letter to Federal Reserve Chairman Powell, Treasury Secretary Mnuchin, HUD Secretary Carson, and FHFA Director Calabria, asking that any credit facility or advances made available to mortgage servicers that purchase loans from correspondents be condition on prohibiting refusals to buy loans or imposing inferior terms and conditions solely due to forbearance status.

CHLA Writes Top Mortgage Regulators Seeking Action and Offering Solutions to Concerns about Small IMB Liquidity

CHLA today wrote a joint letter to Treasury Secretary Mnuchin, HUD Secretary Carson, and FHFA Director Calabria asking for quick action to ensure the liquidity of smaller IMB servciers in the wake of coronavirus and a 2-month foreclosure moratorium – offering solutions to increased advance responsibilities such as Ginnie Mae advances or guarantees of bank loans to IMBs for that purpose.

CHLA Writes FHFA to Seek Suspension of Increased Net Worth and Liquidity Requirements Due to Coronavirus; Also Seeks Small IMB exemption due to their lower financial & systemic risk.

CHLA today wrote the FHFA asking for a suspension of implementation of pending increased net worth and liquidity requirements for GSE servicers, arguing that it would harm access to credit for lenders and borrowers, in the middle of the coronavirus crisis. The CHLA letter also argued that smaller IMBs should be exempt from the requirements, due to their significantly lower financial and systemic risk relative

CHLA Letter to CFPB: USE QM PATCH RULEMAKING TO HELP FACILITATE A GSE UTILITY MODEL

In a novel approach to creating a Utility Model for the GSEs, CHLA suggested in a letter to the CFPB that the QM rule to be used to give FHFA authority to regulate mortgage loan standards for Fannie and Freddie when they exit conservatorship.  The letter also stressed the critical importance of not letting the QM Patch expire without a more flexible replacement.

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