The Center for Responsible Lending (CRL) and the National Community Stabilization Trust (NCST) appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s proposed rule on Protections for Borrowers Affected by the COVID-19 Emergency Under the Real Estate Settlement Procedures Act (RESPA), Regulation X. Our organizations strongly support the Bureau’s goals of preventing avoidable foreclosures and maximizing home retention. However, we believe the proposed rule as drafted will not achieve the stated goals. The Bureau proposes a pre-foreclosure review period through the...
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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Millions of homeowners across the country are having difficulty affording their monthly mortgage payments because of the COVID-19 pandemic. The most vulnerable group of borrowers is concentrated within the Federal Housing Administration (FHA) program, with over 900,000 borrowers who are more than 90 days delinquent. While the CARES Act provided homeowners with access to a mortgage forbearance and while subsequent FHA policy actions have extended these periods, forbearance is an inherently temporary solution. Ultimately, what will determine whether these homeowners are able to stay in their...
Saving for a mortgage down payment is a significant barrier to homeownership that particularly hits communities of color. We calculate how long it would take for a typical renter household to save for a mortgage down payment and closing costs for a median-priced house (“Years to Save”) and further disaggregate these calculations by race/ethnicity, household type, location, and occupation. We also discuss the impact of student loan borrowing on wealth and liquid savings for young households that have attained at least a bachelor’s degree and the likely impact on Years to Save of repaying...
The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Request for Input on Climate and Natural Disaster Risk Management at the Regulated Entities. CRL is a nonprofit, non-partisan research and policy organization dedicated to protecting homeownership and family wealth by working to eliminate abusive financial practices. CRL is an affiliate of Self-Help, one of the nation’s largest nonprofit community development financial institutions. For over 40 years, Self-Help has...
On March 16, 2021, Nikitra Bailey testified in front of the Committee on Banking, Housing, and Urban Affairs during a hearing entitled, "Home = Life: The State of Housing in America." Her written testimony as well as her oral remarks are available for download. Watch Nikitra Bailey's opening remarks and the entire hearing:
On March 10, 2021, Nikitra Bailey testified before the House Financial Services Committee. Her written testimony as well as her oral remarks are available for download. Watch her opening remarks and the entire hearing:
From the comment: The Center for Responsible Lending (CRL) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Resolution Planning proposed rule. FHFA seeks comment on a proposal that would require Fannie Mae and Freddie Mac (GSEs) to develop plans to facilitate their rapid and orderly resolution in the event FHFA is appointed receiver pursuant to 12 U.S.C. 4617. Such a resolution plan, also known as a living will, is to ensure that there is a contingency plan for how a large financial institution will sell off assets or be liquidated without causing turmoil...
The Center for Responsible Lending (CRL)1 appreciates the opportunity to comment on the Affordable Housing Goals Advance Notice of Proposed Rulemaking. In exchange for government support, Fannie Mae and Freddie Mac (GSEs) have an explicit public interest mission. This mission is foundational and part of their charters – the GSEs’ very reason for existing.2 The mission includes promoting access to mortgage credit to underserved borrowers, including Black and brown families, serving a countercyclical role in the mortgage market, and FHFA’s duty to reasonably support the safety and soundness of...
The Center for Responsible Lending and Self-Help filed a joint comment to the Federal Reserve Board on its Advance Notice of Proposed Rulemaking on regulations that implement the Community Reinvestment Act (CRA). Read the full comment.
CRL urges FHFA to provide for a streamlined approval process for the GSEs to submit new activities that do not rise to the level of a new product. Otherwise, given the proposed rule’s extraordinarily broad definition of a new activity, the GSEs will be stymied from pursuing new endeavors by excessive red tape and overly burdensome documentation requirements. A streamlined process is particularly important to encourage innovation in creating additional affordable housing activities and pilots, as well as offer new loss mitigation options for borrowers in a time of crisis such as the COVID‐19...