Comment Detail

Comment

Dear MAA Member:
On May 25th the Federal Housing Finance Agency (FHFA) issued a “request for input” (RFI) to get public views “on issues faced by qualified limited English proficiency (LEP) borrowers to learn more about the procedures and tools that loan originators, servicers, and other parties in the mortgage lending process presently employ to assist LEP borrowers, to identify existing requirements, including laws and regulations that guide practices for interacting with LEP borrowers, and to better understand the challenges in effectively servicing this population.”
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.