A
coalition
of
eight
trade
groups
—
including
the


Housing
Policy
Council
(HPC),
the


Mortgage
Bankers
Association
(MBA)
and
the


Community
Home
Lenders
of
America
(CHLA)
—
have
requested
additional
time
from
the


Consumer
Financial
Protection
Bureau
(CFPB)
to
comment
on

proposed
changes
to
Regulation
X,
which
implements
the
Real
Estate
Settlement
and
Procedures
Act
(RESPA).

Last
week,
the
CFPB
unveiled
a
series
of
proposed
changes
to
Regulation
X
that
would
require

mortgage
servicers
to
emphasize
borrower
assistance
and

loss-mitigation
options
over

foreclosure
when
a
borrower
struggles
to
make
their
required
mortgage
payments.

The
current
due
date
for
comments
on
the
proposal
is
Sept.
9.
While
the
co-signers
agree
that
additional
rulemaking
around
Regulation
X
is
needed,
the
complexity
of
the
new
proposal
is
high
enough
that
the
groups
require
additional
time
to
submit
their
contributions,
according
to
a
letter
sent
to
CFPB
Director

Rohit
Chopra
and
reviewed
by

HousingWire.

“[A]
60-day
comment
period
does
not
provide
sufficient
time
to
meaningfully
address
the
significant
and
potentially
complex
issues,
like
the
new
procedural
review
period,
that
are
covered
by
the
rulemaking,”
the
letter
explained.
“In
addition,
the
servicing
industry
is
still
in
the
process
of
undergoing
massive
program
transformation,
as
a
result
of
policy
changes
made
over
the
course
of
the
pandemic.”

Specifically,
servicers
are
“currently
working
to
execute
servicing
program
changes
for
all
four
of
the


Ginnie
Mae
government
programs
as
well
as
for


Fannie
Mae
and


Freddie
Mac,”
the
letter
said.

Some
of
the
more
significant
challenges
currently
being
worked
through
include
the


U.S.
Department
of
Veterans
Affairs
(VA)
servicing
purchase
(VASP)
program,
a
new
payment
supplement
program
from
the


Federal
Housing
Administration
(FHA)
as
well
as
the
FHA’s
proposed
defect
taxonomy
changes,
and
proposed
changes
to
Fannie
Mae’s
and
Freddie
Mac’s
flex
modification
options.

Each
of
these
proposals
have
upcoming
due
dates
ranging
from
Aug.
26,
2024
to
Jan.
1,
2025,
the
groups
explained.

“The
same
group
of
subject
matter
experts
that
need
to
consider
and
provide
input
on
your
proposal
are
actively
engaged
on
these
other
workstreams,”
the
letter
explained.

The
groups
collectively
request
“at
least”
an
additional
30
days
to
submit
comments
on
the
Regulation
X
proposal.
As
of
Thursday
afternoon,
the
deadline
has
not
yet
been
changed
from
Sept.
9.

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