On June 14, 2017, NAR submitted a letter in response to the Department of Housing and Urban Development’s (HUD) request for comment regarding HUD's effort to evaluate and identify regulations that merit repeal, replacement or modification in accordance with the directives under Executive Order 13777, “Reducing Regulation and Controlling Regulatory Costs.”
NAR strongly supports the programs and policies at HUD that promote home ownership and help build stable and successful communities. Reviewing current HUD guidance, rules and regulations is an important step in ensuring HUD's limited resources are effectively utilized in order to futher its mission of ensuring all Americans have access to a safe, affordable home. NAR urges HUD focus its review efforts as follows:
- Remove the requirement that FHA borrowers with less than a 10 percent down payment pay annual mortgage insurance premiums for the life of the loan. In addition, annual mortgage insurance premiums should be reduced.
- Revise the Federal Housing Administration (FHA) condominium approval regulations to remove restraints on owner-occupancy, FHA concentration, and commercial space limits. FHA should also allow for the return of spot loan approval and reduce the burden of re-certificaton on condominium projects.
- Rescind Mortgagee Letter 2016-11 that allowed for Property Assessed Clean Energy (PACE) loans to take a priority lien position over the government in instances of default or foreclosure.
- Remove prescriptive solutions from the Affirmatively Furthering Fair Housing guidance and give local communities more time to complete the assessment.
- Provide clearer guidelines on service and assistance animals.