The NAACP Legal Defense and Educational Fund, Inc. (LDF) and the Center for Responsible Lending (CRL) submitted a comment in response to the federal financial regulators’ proposed rulemaking on Quality Control Standards for Automated Valuation Study after study has found ongoing, significant undervaluation of homes in communities of color and owned by people of color. Due to decades of past and ongoing discrimination, homes in Black communities and homes owned by Black people are consistently undervalued, contributing to the racial wealth gap. Although some have argued that AVMs can eliminate...
Home ownership has been the primary means for most American families to build and pass on inter-generational wealth. However, government-sanctioned racial discrimination in housing and mortgage finance markets robbed many families of this opportunity, and today’s racial homeownership gap is barely changed from the levels of more than 50 years ago. Closing the homeownership gap is essential to closing the racial wealth gap. Additionally, predatory mortgage lending practices drained trillions in wealth from families, especially Black, Latino, low wealth and low-income Americans. CRL successfully advocated for the Dodd-Frank Wall Street Reform and Consumer Protection Act, which has made the mortgage market far safer for consumers. CRL is building on this progress by working to ensure that all credit-worthy borrowers have access to fair, affordable, and sustainable mortgages. And that policy makers and market participants develop solutions that are appropriate to respond to the scale of this housing crisis.
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CRL submitted a comment on the Federal Housing Finance Agency’s Single Family Pricing Framework arguing that the FHFA should take three steps: Revisit and revise the Enterprise Regulatory Capital Framework, which currently imposes excessive capital requirements on the GSEs; Continue the forward momentum of its recent elimination of LLPA’s for first-time homebuyers and certain affordable housing products by expanding its efforts to reach minority borrowers with increased marketing outreach, special purpose credit programs, etc., and Eliminate upfront guarantee fees for first-generation...
The undersigned organizations wrote in strong support of the Bureau’s proposed rule applying Regulation Z to Residential Property Assessed Clean Energy (PACE) loans. In the proposed rule, the Bureau correctly recognizes that PACE financing fundamentally acts as mortgage credit, yet is provided by underregulated or unsupervised entities that often exploit the lien priority granted to tax assessments. As a result, residential PACE financing should be subject to the same regulations that apply to first-lien mortgages. The rule, if enacted, will significantly limit the well-documented abuses that...
The Consumer Financial Protection Bureau (CFPB) issued a Policy Statement on Abusive Acts and Practices and invited comments from the public. The Center for Responsible Lending applauds the CFPB for its efforts to further clarify abusive acts and practices. The Center further offers insights into how the statement may be strengthened to clarify the ways these acts take unreasonable advantage of a consumer’s inability to protect their interests in selecting or using a product.
This factsheet outlines how H.R. 3564, which would reverse recent FHFA updates to mortgage pricing, would leave borrowers and taxpayers less financially secure.
This CRL letter to Congress expresses support for the Federal Housing Finance Agency (FHFA) updates to its mortgage pricing framework, including FHFA’s assessment on lenders of fees known as Loan Level Pricing Adjustments (LLPAs). The letter also urges Congress to reject H.R. 3564, the so-called Middle-Class Borrower Protection Act, a bill that would rescind FHFA’s recent updates.
CRL and more than 50 organizations committed to gender justice submitted a comment in support of strengthening the Department of Housing and Urban Development (HUD) Proposed Rule on Affirmatively Furthering Fair Housing, which was published in the Federal Register on February 9, 2023 (HUD Docket No. FR 6250-P-01) (Proposed Rule).
Cash-strapped borrowers are being enticed into using the home equity they have accumulated as an ATM and cash-out refinance loans will damage their long-term financial health.
On December 14th, Mitria Spotser, a consultant for the Center for Responsible Lending (CRL) testified before the House Committee on Veterans Affairs hearing on a discussion draft bill, the VA Housing Loan Forever Act of 2022. Her written testimony is available for download and the recorded video is available below.
From the letter to the U.S. Department of Veterans Affairs (VA): The dramatic increase in interest rates since the turn of the year has significantly reduced the effectiveness of VA’s current loan modification program. As a result, an additional loss mitigation option is needed to help veterans who cannot afford to resume their originally scheduled mortgage payments and are in need of payment relief. The refund program gives VA the latitude to adjust the terms of the mortgage without increasing the note rate to the prevailing mortgage rate, which will allow the program to provide the payment...