Joint Letter to HUD on FHA's Single-Family Housing Policy Handbook

US Department of Housing and Urban Development
451 7th Street S.W.
Washington, DC 20410

Dear Sir or Madam:

The Mortgage Bankers Association (MBA), American Bankers Association (ABA), and Housing Policy Council (HPC) (the Associations) appreciate the opportunity to submit joint comments on the proposed changes to the Servicing section of the Federal Housing Administration (FHA) Single-Family Housing Policy Handbook. The Associations commend the steps that FHA and the Department of Housing and Urban Development (HUD) have taken to update its servicing and loss mitigation policies, further aligning with the GSEs.

Attached in the transmittal is the Associations’ Feedback Response Spreadsheet providing our collective and aligned comments in the requested format. Additionally, the Associations would like to use this opportunity to urge HUD to consider several high level recommendations regarding key servicing issues that continue to play a significant role in the cost and availability of FHA loans, as well as some general comments on the Handbook content and rollout plan. These requests include:

• Reform the foreclosure timeline structure 
• Reform the conveyance process by allowing direct conveyance
• Further enhance the Claims Without Conveyance of Title (CWCOT) program following ML 20-21
• Consider additional enhancements to the loss mitigation process and associated waterfall
• Repeal the face-to-face interview requirement
• Allow a reasonable period of time to implement changes in the handbook

Download the comment letter to read the full text.