Mortgage Lending

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 Comment in Opposition to the Implementation of the Proposed HUD Rule on the Housing and Community Development Act of 1980

CRL Comment in Opposition to the Implementation of the Proposed HUD Rule on the Housing and Community Development Act of 1980

CRL opposes the implementation of this proposed rule and any changes to HUD’s current eligibility status. The proposed rule will result in mixed-status families not been able to live as a family unit in subsidized housing. CRL put forth the following arguments in support of its position: The plain text of 42 U.S.C. §1436a(b)(2) and §1436a(c)(1)(A) demonstrates that Congress intended...
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Comment Letter
Mortgage Lending

A Policy-Related Reporting Change, not Increasing Financial Distress, Drove the Late 2025 / Early 2026 Increase in the FHA Serious Delinquency Rate

A Policy-Related Reporting Change, not Increasing Financial Distress, Drove the Late 2025 / Early 2026 Increase in the FHA Serious Delinquency Rate

The 90D+ delinquency (DQ) rate on loans insured by the Federal Housing Administration (FHA), which captures loans that are 90 or more days delinquent but not in foreclosure or bankruptcy, has increased sharply. At 3.57% in September 2025, it has since risen to 5.23% in January 2026, an increase of 1.66 percentage points (pp) in just 4 months. Market commentators...
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Policy & Legislation
Mortgage Lending

Recommendations for Implementing a Cost-Effective VA Loss Mitigation Program

Recommendations for Implementing a Cost-Effective VA Loss Mitigation Program

The Department of Veterans Affairs (VA) holds 25% of the risk of loss associated with borrower default on VA-guaranteed mortgages. Therefore, VA has an economic interest in directing mortgage servicers to engage in risk management techniques that will reduce the number of defaults on VA-guaranteed loans that transition to disposition (i.e., foreclosure, short sale, or deed-in-lieu of foreclosure) and cause...
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Policy & Legislation
Mortgage Lending

Comment on Federal Housing Finance Agency’s Notice of Proposed Rulemaking on the 2026-2028 Enterprise Housing Goals

Comment on Federal Housing Finance Agency’s Notice of Proposed Rulemaking on the 2026-2028 Enterprise Housing Goals

The Center for Responsible Lending agrees with the Federal Housing Finance Agency on the importance of acting intentionally and swiftly to positively address this nation’s housing challenges but believe that the proposed rule will not have the desired effect. Specifically: by reducing the low-income purchase goal by 4 percentage points (25% to 21%) for the next three years, nearly cutting...
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Comment Letter
Mortgage Lending

Consumer Organizations and Attorneys Urge the Consumer Financial Protection Bureau to Issue a Final PACE Rule

Consumer Organizations and Attorneys Urge the Consumer Financial Protection Bureau to Issue a Final PACE Rule

The undersigned consumer organizations and attorneys write to urge the Consumer Financial Protection Bureau to issue a final PACE rule. Last year, we applauded the Bureau for proposing a strong rule that would ensure PACE borrowers receive critically important consumer protections under Regulation Z. But the proposed rule came five years after Congress amended the Truth in Lending Act (TILA)...
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Letters to Congress
Mortgage Lending

New Homes with Mortgages Backed by the Enterprises Should Meet Updated Building Energy Code Requirements

New Homes with Mortgages Backed by the Enterprises Should Meet Updated Building Energy Code Requirements

More than 120 affordable housing, consumer, health, energy efficiency, environmental, business, and other organizations at the national, state, and local levels joined this letter to urge the FHFA to direct the Government Sponsored Enterprises, Fannie Mae and Freddie Mac, to join the Department of Housing and Urban Development (HUD) and the Department of Agriculture (USDA) in requiring that all new...
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Letters to Congress
Mortgage Lending Clean Energy Transition

Comment on Freddie Mac Proposed Purchase of Single-Family Closed-End Second Mortgages

Comment on Freddie Mac Proposed Purchase of Single-Family Closed-End Second Mortgages

From the comment's introduction: Many mortgage lenders are willing to offer cash-out refinances because the Government Sponsored Enterprises (GSEs) Fannie Mae and Freddie Mac, the Federal Housing Administration (FHA), or the Department of Veterans Affairs (VA) bear the credit risk. However, fewer lenders are willing to make home equity loans, especially to borrowers with lower credit scores, given the associated...
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Comment Letter
Mortgage Lending

Recommendations on How FHA Should Shape Its Post-COVID Loss Mitigation Waterfall

Recommendations on How FHA Should Shape Its Post-COVID Loss Mitigation Waterfall

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...
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Letters to Congress
Mortgage Lending
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