NRMLA Submits Letters to HUD, State Lawmakers NRMLA, with input from our committees, submits comments throughout the year to the U.S. Department of Housing and Urban Development (HUD), Consumer Financial Protection Bureau and other regulators that seek public feedback on proposed regulatory changes and to state lawmakers when they introduce bills that could impact reverse mortgage lenders and servicers. Here are just a few recent examples: • NRMLA offered recommendations to HUD to make the assignment process for HECMs more efficient and to further reduce liquidity risk to mortgagees. HUD published a draft mortgagee letter on April 4 that proposed changes to the HECM Assignment Claim Type 22 submission criteria and requested feedback. Among its recommendations, NRMLA proposed that in lieu of requiring mortgagees to provide a current hazard and, if applicable, flood insurance declaration page in the compliance package, the Federal Housing Administration (FHA) should permit mortgagees to provide electronic evidence that such insurance is in force and in effect, as well as coverage amounts. • NRMLA sent a letter to New York Assemblyman David I. Weprin in mid-April in response to Assembly Bill 5877 that he introduced to repeal Section 280-a of the New York Real Property Law and amend Section 280 of the New York Real Property Law. The bill would raise the minimum age to obtain a reverse mortgage from 60 to 62 and disallow any fees from being charged for the processing of a reverse mortgage until a lender receives a signed counseling certificate. In its letter, NRMLA asked Weprin to consider lowering the minimum borrower age to 55 to accommodate younger homeowners who may wish to obtain a proprietary reverse mortgage. NRMLA also recommended that the bill clarify that prior to receiving the counseling certificate, lenders may order certain services, such as an automated valuation model, credit report or preliminary credit review, as long as the borrower is not charged for those services if the borrower chooses not to get a reverse mortgage. • NRMLA supported a draft HUD proposal to allow income from accessory dwelling units (ADUs) to be used in qualifying borrowers for FHA-insured mortgages, including HECMs. “Permitting the inclusion of income from an ADU in the assessment of a HECM borrower’s income will more realistically calculate the borrower’s effective income and potentially expand program eligibility in a prudent manner,” NRMLA said in its comment letter to HUD. FHA Hires New Deputy Assistant Secretary Sarah Edelman joined the Federal Housing Administration in March as deputy assistant secretary for single-family housing after working for five years at Fannie Mae as senior director of environmental and social impact. In her new role, Edelman will have direct supervision over the HECM program. She replaces Julienne Joseph, who became a senior adviser for the U.S. Department of Housing and Urban Development Secretary Marcia Fudge. A Roundup of Issues and News for NRMLA Members By Darryl Hicks Darryl Hicks Hey, Members 8 REVERSE MORTGAGE / JULY–AUGUST 2023
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