Advocacy
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 Joins Broad Coalition in CFPB Letter Outlining Proposal to Preserve QM Ability to Repay, With Appropriate Flexibility
CHLA joined with a broad coalition including the National Association of Realtors, consumer groups, USMI, and other small lender groups in offering a proposal to retain essential elements of the QM Ability to Repay standard, but with a more flexible Debt to Income (DTI) which includes other underwriting criteria in the form of Compensating Factors
CHLA Supports Administration GSE Reform Proposal to Make Small-Lender GSE Parity Policy Permanent
The Community Home Lenders Association wrote FHFA and the Treasury Department to express strong support for the proposal in the Administration’s housing finance reform plan to make small lender GSE parity permanent, as part of a revision of the Preferred Stock Purchase Agreements (PSPA).
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.
CHLA Releases its Latest “GSE Reform Plan”
CHLA today released its updated GSE reform plan, following the administrative approach to GSE reform CHLA has been advocating for 5 years. Citing the substantial reforms accomplished to date, CHLA called on FHFA and Treasury to finish the task by ending the GSE Profit Sweep, finalizing a capital rule, and carrying out a Capital Restoration Plan, that results in an end to the GSEs’ conservatorship.
CHLA Comment Letter to Ginnie Mae: Stress Testing is Not Appropriate for Smaller IMB Issuers
CHLA submitted a comment letter to Ginnie Mae, arguing that Ginnie Mae should not stress test smaller IMB issuers, as stress testing would not accurately measure smaller issuer risk, would undermine consumer access to credit, and would increase issuer concentration. The letter drew heavily from CHLA’s January “Report on Ginnie Mae.”
CHLA Joins Other Groups in Letter to FHA to Eliminate Indemnification Penalties for New Loans with Forbearance
CHLA, along with consumer groups and other trade groups, sent a letter to HUD Secretary Ben Carson, asked FHA to eliminate its recently adopted 20%
Housing Wire: FHA enacts temporary policy shift on forbearances; CHLA pushes back on 20% first loss penalty
A Housing Wire article on FHA’s announcement that it would impose a 20% first loss indemnification penalty on validly underwritten loans that go into forbearance
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