The National Consumer Law Center, on behalf of its low-income clients, and the Center for Responsible Lending write with recommendations on how FHA should shape its post-COVID loss mitigation waterfall. As the market turns from a response to COVID-19 to identifying permanent policies informed by lessons learned from the pandemic, FHA has an opportunity to strengthen the options it makes available to homeowners facing hardship. FHA has shown leadership in developing innovative foreclosure alternatives that provide relief in any market condition. We believe FHA should build its long-term loss mitigation waterfall from the innovative options it has already created.

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