Comment Detail

Comment

MBA strongly supports efforts to expand homeownership opportunities and looks forward to working with FHFA and others towards that goal. MBA will respond to this RFI to encourage FHFA to provide guidance on how GSE originators and servicers can better serve the LEP population and share best practices from our members who lead in this area.
One idea that MBA cannot support is the possibility that FHFA would put a question regarding a borrower’s “preferred language” on the Uniform Residential Loan Application (URLA) that all GSE borrowers or their lender must complete. A year ago, MBA and other industry groups were able to convince FHFA to focus on developing resources and guidance to assist LEP borrowers before putting this question on the form. However, it appears that FHFA is contemplating doing so again, despite many issues and potential risks that remain unaddressed.
We believe that inclusion of such a question would be premature and potentially harmful to a lender or servicer’s relationship with their customer The borrower might have expectations about service in another language that a lender or servicer cannot provide, or a borrower might erroneously believe the lender intended to discriminate against them or otherwise treat them differently. Neither outcome is consistent with the type of customer service we know MBA members strive to provide.