Empire Justice Comments on Protecting the Mortgage Insurance Fund

Ellie Pepper June 14, 2017

Regulations Division
Office of General Counsel
Department of Housing and Urban Development
451 7th Street S.W., Room 10276
Washington, DC 20410-0500

RE: Comments to Office of Secretary, HUD on 82 Federal Register 22344; Docket No. FR-6030-N-01; Reducing Regulatory Burden; Enforcing the Regulatory Reform Agenda Under Executive Order 13777

Dear Regulations Division:

Empire Justice Center is pleased to have the opportunity to provide comments to HUD’s request for input on its regulatory program.  Empire Justice Center is a New York State-wide, multi-issue, multi-strategy, public interest law firm focused on changing the systems in which poor and low income families live.  Empire Justice Center protects and strengthens the legal rights of people in New York State who are poor, disabled or disenfranchised through systems change advocacy, training and support to other advocates and organizations, and high quality direct civil legal representation.  Empire Justice has offices in Albany, Rochester, Westchester and Long Island.

Our comments will focus on how HUD’s current foreclosure alternatives program for FHA-insured loans avoids unnecessary payment of insurance claims, and thus protects the mortgage insurance fund (Fund) and our communities.  Payment of unnecessary claims harms the Fund and destabilizes neighborhoods.  We will also illustrate the importance of HUD approved housing counseling to ensure homebuyers get a mortgage that is sustainable, and that homeowners are able to avoid foreclosure.

CLICK HERE to read our comments in full.

For more information, please contact:

Ellie Pepper
Empire Justice Center
119 Washington Avenue
Albany, NY  12210
(518) 462-6831
(518) 935-2852