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Comment to the Federal Housing Finance Agency on Prior Approval for Enterprise Products

January 8, 2021
Mortgage Lending
Comment Letter

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 pandemic that is disproportionately impacting Black and brown families and other lower‐wealth Americans.