03 Jul That it requirements has not averted lenders otherwise servicers regarding getting into energetic losses minimization efforts
Issue: A beneficial commenter indicated concern that requiring a “necessary” matchmaking will get hinder loss minimization efforts, as well as those in House Sensible Amendment System (HAMP) and you can Family Sensible Refinance System (HARP)-government applications you to encourage financial servicers to offer changes away from fund or refinances-once the like work is voluntary and you may involvement in them may well not become perceived as “expected.”best hookup apps married
In addition, because an effective commenter noted, the brand new Government Legislation out of Municipal Process provide individuals methods to get rid out of meritless states, and additionally Regulations eleven, several, and you will 56
HUD Response: Just like the at the least the newest go out out of issuance of the Mutual Policy Declaration from inside the 1994, lenders was basically on the see that they must prove the necessity of a pushed habit on the providers below the Fair Property Work and ECOA. The newest mere proven fact that a policy is willingly used will not prevent they regarding are wanted to get to a substantial, genuine, nondiscriminatory desire.