2101 Wilson Boulevard, Suite 610
Arlington, VA 22201
April 21, 2015
Ms. Kathleen Zadareky
Deputy Assistant Secretary for Single Family Housing
U.S. Department of Housing and Urban Development
451 7th Street, S.W.
Washington, D.C. 20410
Dear Deputy Assistant Secretary Zadareky:
The Community Home Lenders Association (CHLA) writes to request a delay in the implementation of the FHA Single Family Housing Policy Handbook until January 1, 2016.
The Community Home Lenders Association is the only national trade association that exclusively represents non-bank mortgage lenders. Our small and mid-sized community based lenders are integral parts of their respective communities, and play a significant role in FHA origination.
CHLA strongly supports HUD’s effort to develop a comprehensive FHA Handbook.
However, we are concerned about the rapid pace in which HUD proposes to implement the Handbook. The schedule calls for a June 15th implementation date. If this were simply a process of gathering Mortgage Letters and other guidance into once place, timing would not be an issue. However, other changes are being incorporated.into the Handbook And, the complete Handbook has not been released and lenders have been unable to train staff or adapt operations.
CHLA is concerned the proposed deadline may negatively impact access to credit for consumers. CHLA believes that consumers will be better served by a process that allows for enough time for lenders to fully understand and prepare for the changes incorporated in the Handbook.
Moreover, the June 15 deadline coincides with a major lender responsibility to adjust to significant RESPA-TILA changes shortly thereafter. As industry education adjustments require state regulatory approval, the amount of change scheduled within a relatively short window of time is significant and potentially harmful to the ability of a consumer to obtain an FHA loan.
Accordingly, while CHLA looks forward to continuing dialogue with HUD on implementation of the Handbook, we respectfully request a delay in its implementation until January 1, 2016.
Community Home Lenders Association