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Timeline of Key COVID-19 Policy Responses Affecting Housing and Mortgage Markets

The Brief
  • Once it became clear that the COVID-19 pandemic would have serious financial ramifications for households and businesses, the Trump administration, Congress, and federal financial regulatory agencies acted.
  • With their responses and guidance constantly evolving (and sometimes mutating), it is important policymakers and the public follow along and endeavor to understand the collective impact of these actions.
  • This blog post will be periodically updated to help track steps taken to-date by the federal government to lower interest rates, preserve market liquidity, provide regulatory relief, keep renters and homeowners stably housed, and assist those experiencing homelessness.

May Response Timeline

  • HUD allocated $685 million in CARES Act funding – May 1

    The Department of Housing and Urban Development announced it would be allocating about $685 million in a second wave of CARES Act funding. These funds were awarded through the Public Housing Operating Fund to public housing authorities. HUD also announced that public housing authorities may use operating funds and capital funds previously allocated for COVID-19 preparation, prevention, and response efforts.

  • Ginnie Mae first published data from its COVID-19 issuer assistance program

    Ginnie Mae published the first set of data related to its expanded Pass-Through Assistance Program, developed in response to the COVID-19 national emergency. The program allows issuers to apply for assistance in meeting their contractual obligation to make timely and in-full principal and interest payments due mortgage-backed security holders without being held in default.

  • HUD released FAQs on the CARES Act Eviction Moratorium and HOME Program

    In a guidance document, HUD’s Office of Affordable Housing Programs responded to frequently asked questions on Section 4024 of the CARES Act, which imposed a temporary moratorium on evictions, and how it applies to covered dwelling units assisted by HUD’s HOME Program.

  • Ginnie Mae expanded its COVID-19 issuer assistance program

    In All Participants Memorandum 20-05, Ginnie Mae announced the expansion of its issuer assistance programs in response to the COVID-19 national emergency. The memo introduced a new version of the existing Pass-Through Assistance Program for use by multifamily mortgage-backed securities issuers facing a temporary liquidity shortfall due to the COVID-19-related financial hardships. The assistance is intended to minimize disruptions in the mortgage servicing and capital markets as borrower forbearance and loss mitigation programs are implemented to help provide relief to renters.

  • HUD released waiver memo for CARES Act grant funding

    HUD’s Office of Community Planning and Development released a memorandum urging states and localities not to wait to apply for their Emergency Solutions Grants and Housing Opportunities for Persons With AIDS coronavirus response allocations. The memorandum also granted a waiver for plan amendments with instructions on how a grantee may submit an amendment to incorporate emergency allocations into their most recent annual action plan.

  • FHFA announced online multifamily property lookup tools

    The Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac created online multifamily property lookup tools to help renters find out if they are protected from evictions during the COVID-19 national health emergency. The property lookup tools allow renters to find out if the multifamily property where they reside has a Fannie- or Freddie-backed mortgage, which covered by a temporary eviction moratorium under the CARES Act.

  • HUD allocated $380 million to public housing authorities

    HUD announced it would be allocating about $380 million in supplemental administrative fee funding to all public housing authorities. This funding could cover new eligible coronavirus-related activities, including sanitation, transportation to health units and testing, childcare, food, and medical supplies.

  • FHFA extended loan processing flexibilities for Fannie Mae and Freddie Mac customers

    The Federal Housing Finance Agency extended several loan origination flexibilities offered by Fannie Mae and Freddie Mac to help borrowers during the COVID-19 national emergency. Those flexibilities were extended until at least June 30 and include alternative appraisals on purchase and refinance loans, employment verification alternatives before loan closing, flexibility on documentation, and expanded use of power of attorney and remote online notarizations. Details from Freddie Mac and Fannie Mae were released in Bulletin 2020-14 and an updated Lender Letter 2020-03.

  • Financial regulators modified banks’ liquidity coverage ratio

    Effective immediately, federal bank regulatory agencies announced an interim final rule that modified the agencies’ Liquidity Coverage Ratio rule to support banks’ participation in the Federal Reserve’s Money Market Mutual Fund Liquidity Facility and the Paycheck Protection Program Liquidity Facility, by neutralizing the rule’s impact on the non-recourse funding these facilities provide. The Liquidity Coverage Ratio rule requires large banks to hold a buffer of high-quality liquid assets so that they can meet short-term liquidity needs.

  • Fed and FDIC extend deadlines for large bank resolution plans

    The Federal Reserve and Federal Deposit Insurance Corporation jointly extended the submission date by 90 days, to September 29, 2021, for the targeted resolution plans from large foreign and domestic banks in Category II and Category III of the agencies’ large bank regulatory framework. A full list of these banks can be found here: https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200506a1.pdf

  • HUD provided CARES Act HOPWA grant implementation instructions and flexibilities

    HUD released Notice CPD-20-05, providing instructions for implementing CARES Act provisions relating to the Housing Opportunities for Persons With AIDS program and other information for grantees. It also encouraged grantees to immediately initiate the necessary processes to obtain their allocations to assist in the COVID-19 response.

  • VA updated its guidance on loan valuations

    In Circular 26-20-13, the Department of Veterans Affairs provided further clarification on the effective date of the temporary guidance and additional information it has released regarding valuation practices for its loan programs during the COVID-19 national emergency.

  • HUD allocated $1 billion in CARES Act funding

    HUD announced it would be allocating about $1 billion in a third wave of CARES Act funding, distributed through HUD’s Community Development Block Grant program with a formula focused on public health needs, risk of transmission of coronavirus, rate of coronavirus cases, and economic disruption.

  • Fed updated the term sheet for the Municipal Liquidity Facility

    The Federal Reserve published updates to the term sheet for the Municipal Liquidity Facility to provide pricing and other information. The Municipal Liquidity Facility was established to offer $500 billion in lending to states and municipalities to help manage cash flow stresses caused by the coronavirus pandemic.

  • Federal agencies launched joint housing assistance website for those impacted by COVID-19

    The Consumer Financial Protection Bureau, Federal Housing Finance Agency, and the Department of Housing and Urban Development jointly launched a new mortgage and housing assistance website to ensure homeowners and renters have the most up to date and accurate housing assistance information during the COVID-19 national emergency.

  • Fed update the term sheet for the Term Asset-Backed Securities Loan Facility and announced new disclosures

    The Federal Reserve provided additional information regarding borrower and collateral eligibility criteria for the Term Asset-Backed Securities Loan Facility, which was announced on March 23 to make up to $100 billion of loans available to support the flow of affordable credit to U.S. consumers and businesses. The Federal Reserve also outlined the information it will publicly disclose for the facility and the Paycheck Protection Program Liquidity Facility on a monthly basis—including the names of participants in both facilities; the amounts borrowed, interest rates charged, and value of pledged collateral; and the overall costs, revenues, and fees for each facility. The disclosures are similar to those announced in April for the Board facilities that utilize CARES Act funds.

  • FHFA announced a new payment deferral option for homeowners in forbearance plans

    To help borrowers who are in COVID-19 related forbearance, the Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac would make available a new payment deferral option, giving those able to return to making their normal monthly mortgage payment the ability to repay their missed payments at the time the home is sold, refinanced, or at maturity. Details from Fannie Mae and Freddie Mac are included in Lender Letter 2020-07 and Bulletin 2020-15.

  • HUD extended eviction and foreclosure moratorium and other guidance

    In Mortgagee Letter 2020-13, HUD announced the moratorium on evictions and foreclosures for properties with Federal Housing Administration-backed loans would be extended until June 30, 2020. In Mortgagee Letter 2020-14, HUD also extended the effective date of Mortgagee Letter 2020-05, which was released on March 27, and provided guidance on employment and appraisal requirements.

  • FHFA extended foreclosure and eviction moratorium

    The Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac extended their moratorium on foreclosures and evictions (Fannie- or Freddie-backed, single-family mortgages only) from May 17, 2020 until at least June 30, 2020. Fannie Mae and Freddie Mac also provided updates on their temporary mortgage servicer guidance in a revised Lender Letter 2020-02 and Bulletin 2020-16.

  • VA extended foreclosure moratorium for borrowers affected by COVID-19

    In Circular 26-20-18, the Department of Veterans Affairs announced the moratorium on foreclosures for borrowers with VA-backed loans would be extended until June 30, 2020.

  • HUD published methodology for additional CARES Act fund allocations

    The CARES Act required HUD to allocate $1 billion in community development block grants (out of a total emergency appropriation of $5 billion) to state and insular area governments by May 11, 2020. HUD released a document describing the methodology for this second round of CARES Act Community Development Block Grant funding, intended to target public health, coronavirus, and housing and economic disruption needs.

  • Federal bank regulators temporarily changed their supplementary leverage ratio rule

    The Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency announced temporary changes to their supplementary leverage ratio rule to provide flexibility to certain depository institutions to expand their balance sheets and provide credit to households and businesses in light of the challenges arising from the coronavirus response.

  • HUD allocated $77 million in CARES Act funding

    HUD announced it would be allocating about $77 million in a fourth wave of CARES Act funding to provide 8,300 additional housing vouchers through HUD’s Section 811 program for people with disabilities.

  • HUD issued memo on performance report waiver

    HUD’s Office of Community Planning and Development’s released a memorandum authorizing and explaining a waiver of the regulatory requirement, 24 CFR 91.520(a), requiring grantees to submit a performance report known as the Consolidated Annual Performance and Evaluation Report.

  • President Trump issued executive order on regulatory relief

    President Trump signed an executive order directing federal agencies to cut regulations to help the economy recover from the impact of COVID-19.


  • FHFA announced refinance and home purchase eligibility for borrowers in forbearance

    To support borrowers and mortgage servicers, the Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac have issued temporary guidance regarding the eligibility of borrowers who are in forbearance, or have recently ended their forbearance, looking to refinance or buy a new home. The Federal Housing Finance Agency also extended the ability to purchase single-family mortgages in forbearance previously announced. Details from Fannie Mae and Freddie Mac were included in revised Lender Letter 2020-03, revised Lender Letter 2020-06, and Bulletin 2020-17.

  • VA issued additional lender guidance concerning COVID-19

    In Circular 26-20-19, the Department of Veterans Affairs reminded lenders of current VA policies and provided further guidance to assist the processing of VA-guaranteed loans during the COVID-19 national emergency.

  • Financial regulators released principles for responsible small-dollar loans

    Building on a joint agency statement released on March 26, the Federal Reserve, Federal Deposit Insurance Corporation, National Credit Union Administration, and the Office of the Comptroller of the Currency issued principles for offering small-dollar loans in a responsible manner to meet financial institutions customers’ short-term credit needs. The principles were released to encourage supervised banks, savings associations, and credit unions to offer responsible small-dollar loans, recognizing the role such loans can play in helping customers meet their ongoing needs for credit from temporary cash-flow imbalances, unexpected expenses, or income shortfalls, including during periods of economic stress, natural disasters, or other extraordinary circumstances such as the public health emergency created by COVID-19.

  • FHFA re-proposed capital rule for Fannie and Freddie

    The Federal Housing Finance Agency released a notice of proposed rulemaking to establish a new regulatory capital framework for Fannie Mae and Freddie Mac, a re-proposal of the notice of proposed rulemaking published in July 2018. The rule would stablish new risk-based capital requirements for Fannie Mae and Freddie Mac, update their minimum leverage requirement, and further FHFA’s stated intention to end their conservatorship.

  • HUD announced additional regulatory waivers for grant programs

    In a memorandum, HUD announced it was making available regulatory waivers and one NOFA requirement associated with several HUD grant programs: Housing Opportunities for Persons with AIDS, Continuum of Care, Youth Homelessness Demonstration Program, and the Emergency Solutions Grants Program.

  • HUD guidance allowed electronic signatures and documents

    In Housing Notice 2020-04, HUD’s Office of Multifamily Housing issued guidance for the use of electronic signatures, as well as file storage and transmission, in HUD-assisted multifamily housing. The guidance is intended for industry

  • HUD extended effective date of interim procedures

    HUD extended the effective date of Mortgagee Letter 2020-10, issued on April 10 and which temporarily modified the established process for on-site inspections at residential care facilities in its Section 232 mortgage insurance program, given the Centers for Medicare & Medicaid Services order to restrict visitors and non-essential health care personnel.

  • Fannie and Freddie update guidance on self-employment income

    Fannie Mae updated Lender Letter 2020-03 and Freddie Mac released Bulletin 2020-19 to provide guidance on requirements for borrowers using self-employment income to qualify for loans.

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April Response Timeline

  • HUD announced the availability of regulatory waivers for its grant programs – April 1

    HUD issued a memorandum providing regulatory waivers of certain Continuum of Care, Emergency Solutions Grant, Housing for Persons with AIDS, and consolidated plan requirements.

  • HUD announced mortgage relief policies in accordance with the CARES Act – April 1

    HUD announced and published Mortgagee Letter 2020-06 to implement the mortgage forbearance provisions provided the CARES Act, signed into law on March 27, for Federal Housing Administration-insured mortgages. The letter outlined loss mitigation options for borrowers experiencing a financial hardship because of COVID-19, including the availability of up to six months of mortgage payment forbearance (and an additional six-month period, if needed) and a new COVID-19 national emergency standalone partial claim for eligible borrowers. The partial claims process will allow servicers to recuperate funds advanced during the forbearance period.

  • Fed moved to boost big bank liquidity – April 1

    The Federal Reserve implemented temporary changes to its supplemental leverage ratio rule to increase the ability of large banks to provide credit during the crisis.

  • Consumer Financial Protection Bureau outlined credit reporting responsibilities – April 1

    The CARES Act required lenders to report to credit bureaus that consumers are current on their loans if they have sought relief from their lenders due to the COVID-19 pandemic. CFPB released a policy statement informing lenders they must comply with those provisions of the CARES Act.

  • HUD posted initial CARES Act supplemental funding allocations – April 2

    HUD posted the fiscal year 2020 CARES Act supplemental funding to states and local governments, including $2 billion in Community Development Block Grants, $1 billion in Emergency Solutions Grants, and $63.7 million in Housing Opportunities for Persons with AIDS formula funds and competitive grants.

  • Financial regulators issued guidance on mortgage servicing – April 3

    Federal and state financial regulators issued a joint statement providing guidance to residential mortgage loan servicers regarding forbearance measures under the CARES Act and the Real Estate Settlement Procedures Act’s Regulation X servicing requirements. The joint statement addresses flexibility provided to servicers that work with COVID-19 affected borrowers eligible for mortgage payment forbearance regarding compliance with loss mitigation, early intervention, and annual escrow statement requirements under Regulation X.

  • Federal bank regulators changed the community bank leverage ratio – April 6

    To implement Section 4012 of the CARES Act, federal bank regulatory agencies—the Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency—released two interim final rules that temporarily lower the community bank leverage ratio to 8%. The move is intended to help community banks lend.

  • Fed created Payroll Protection Program Lending Facility - April 6

    The Federal Reserve announced the Payroll Protection Lending Facility to provide credit to banks making loans under the CARES ACT’s Payroll Protection Program, increasing their lending capacity in the face of high demand to originate the loans.

  • Financial regulators revised interagency statement on loan modifications – April 7

    Federal financial regulators, in consultation with state financial regulators, released a revised interagency statement to reconcile their March 22 statement with provisions in the CARES Act. The revised statement included the agencies’ views on consumer protection considerations.

  • Fannie and Freddie updated COVID-19 servicing guidance – April 8

    In an update to Lender Letter 2020-02 and Bulletin 2020-10, Fannie Mae and Freddie Mac announced updates to their temporary servicing guidance due to COVID-19, accounting for the adoption of the CARES Act and reminding services of their compliance obligations.

  • USDA expanded loan servicing options – April 8

    Building on servicing options announced March 31 for guaranteed lenders, and to comply with the CARES Act, the Department of Agriculture announced:

    • Guaranteed lenders may approve and make covered loans pursuant to the CARES Act’s Small Business Administration-guaranteed Paycheck Protection Program.
    • Lenders must provide immediate forbearance to borrowers facing financial hardship for USDA’s Single-Family Housing Guaranteed Loan program for a period of up to 180 days, which may be further extended another 180 days thereafter.
    • Tenants in USDA-financed multifamily housing cannot be evicted for nonpayment of rent until July 25, 2020.
    • Multifamily borrowers can request forbearance for up to 180 days.
  • Fed announced it will provide up to $2.3 trillion in loans – April 9

    The Federal Reserve issued a press release announcing that it would provide up to $2.3 trillion in loans to support the economy. Importantly, their actions will:

    • Supply liquidity to participating financial institutions through the Paycheck Protection Program Liquidity Facility to extend credit to eligible financial institutions that originate PPP loans
    • Ensure credit flows to small- and mid-sized businesses with the purchase of up to $600 billion in loans to businesses with up 10,000 employees or up to $2.5 billion in revenues, through a new Main Street Lending Program
    • Expand the size and scope of its Primary and Secondary Market Corporate Facilities and Term Asset-Backed Securities Loan Facility
    • Establish a Municipal Liquidity Facility that will purchase up to $500 billion in state and municipal debt in response to higher yields and reduced liquidity
  • HUD announced flexibilities for Community Development Block Grant funds – April 9

    HUD released a memorandum on plan amendments and expanded eligible uses, as authorized by the CARES Act.

  • FEMA temporarily suspended rents – April 9

    FEMA issued a temporary suspension on rent for disaster survivors living in FEMA housing in California, Florida, North Carolina, and Texas to help ease the financial burden on survivors as a result of the COVID-19 pandemic.

  • Ginnie Mae expanded its issuer assistance program – April 10 


    In All Participants Memorandum 20-03, Ginnie Mae revised and expanded its issuer assistance programs, implementing a new Pass-Through Assistance Program for the COVID-19 National Emergency. Approved issuers may request an advance for the difference between an issuer’s available funds and scheduled payment to investors. Like Ginnie’s existing Disaster Assistance Program, such requests are intended only as a last resort.

  • HUD implemented CARES Act-required forbearance and provided other guidance – April 10

    In three mortgagee letters, HUD implemented requirements under the CARES Act and provided new guidance given COVID-19’s impact on real estate markets:

    • Mortgagee Letter 2020-09 provided the protocol to request mortgage forbearance for Federal Housing Administration-insured loans as required by the CARES Act. That authority is under effect from March 27 through the end of the year, unless the national emergency declaration is terminated before then.
    • Mortgagee Letter 2020-10 temporary modified the established process for on-site inspections at residential care facilities in its Section 232 mortgage insurance program, given the Centers for Medicare & Medicaid Services order to restrict visitors and non-essential health care personnel.
    • Mortgagee Letter 2020-11 provided debt service reserve requirements for HUD’s 223(f) loans in process due to the impact of COVID-19 on the real estate market. The requirements will remain in effect until HUD determines the real estate markets have stabilized.

    These steps were summarized in a HUD media advisory released on April 13.

  • HUD granted public housing authorities and tribes waiver authority – April 10

    In Notice PIH 2020-05, HUD outlined for public housing authorities, tribes, and tribally designated housing entities the waiver authorities being granted for the public housing, housing choice voucher, and Native American programs.

  • Coronavirus Relief Fund web portal went live – April 14

    The Treasury Department launched a web portal to allow eligible state, local, and tribal governments to receive payments to help offset the costs of their response to the COVID-19 outbreak. Through the Coronavirus Relief Fund, the CARES Act provided for payments to governments navigating the impact of COVID-19. Government eligible for payments were required to submit payment information and supporting documentation by April 17, 2020.

  • HUD updated guidance for Home Equity Conversion Mortgages – April 14

    In Mortgagee Letter 2020-12, HUD issued guidance to provide Federal Housing Administration-insured home equity mortgagees with additional flexibilities during the COVID-19 National Emergency, such as offering temporary alternative forms of acceptable documentation and granting extensions for delivering physical documents.

  • Federal banking regulators deferred appraisals and evaluations – April 14

    The Federal Reserve, Federal Deposit Insurance Corporation, Office of Comptroller of the Currency, National Credit Union Administration, and Consumer Financial Protection Bureau jointly issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under their interagency appraisal regulations for up to 120 days after the closing of certain residential or commercial real estate loan transactions. The temporary provisions will expire December 31, 2020. In consultation with the Conference of State Bank Supervisors, they also released a joint statement outlining other flexibilities in industry appraisal standards and regulations, describing temporary changes to Fannie Mae and Freddie Mac appraisal standards and discussing how they will continue to communicate with the industry.

  • HUD provided guidance on the HOME program – April 14

    HUD issued two memoranda to provide guidance and the necessary statutory suspensions and regulatory waivers that apply to HOME Participating Jurisdictions affected by the COVID-19 pandemic—a memo on statutory suspensions and regulatory waivers so HOME funds can help address immediate housing needs and a memo on statutory suspensions and regulatory waivers intended to enable the use HOME tenant-based rental assistance.

  • CFPB and FHFA launched servicing information sharing – April 15

    The Consumer Financial Protection Bureau and FHFA announced a new joint initiative that enables them to share servicing information to protect borrowers during the COVID-19 national emergency. Via a secure electronic interface, CFPB will provide its compliant information and analytical tools and FHFA will provide information about loan forbearances, modifications, and other loss mitigation initiatives undertaken by Fannie Mae and Freddie Mac.

  • HUD announced expedited process Continuum of Care Program grant amendments – April 17

    HUD’s Office of Special Needs Assistance Programs has determined that an expedited process is necessary for amending Continuum of Care Program recipient grant agreements to better provide housing, services, and other necessities for those affected by COVID-19.

  • HUD posted the FY 2020 formula program allocations – April 21

    HUD posted the fiscal year 2020 allocations for the Office of Community Planning and Development’s formula programs: the Community Development Block Grant, CDBG Recovery Housing Program, Emergency Solutions Grants, HOME Investment Partnerships Program, Housing Opportunities for Persons With AIDS, and Housing Trust Fund.

  • HUD expedited the grant agreement amendment process for the Continuum of Care program – April 21

    HUD’s Office of Special Needs Assistance Programs determined that an expedited process was necessary for amending Continuum of Care program recipient grant agreements to provide housing, services, and other necessities in response to COVID-19.

  • FHFA announced 4-month advance obligation limit for loans in forbearance - April 21

    In the CARES Act, Congress stipulated that homeowners harmed by the COVID-19 pandemic be permitted to suspend payments for as long as a year without penalty. This ignited concerns about the liquidity and stability of mortgage servicers, who are contractually obligated to advance borrower payments to end investors even when loans are in forbearance. To address these concerns, FHFA capped the amount of missed borrower payments a servicer must cover at four months.

  • FHFA announced that Fannie and Freddie will purchase qualified loans in forbearance - April 22

    Due to the pandemic, some borrowers have sought payment forbearance shortly after closing on their single-family loan and before their lender can deliver the mortgage loan to Fannie Mae and Freddie Mac. FHFA approved having Fannie Mae and Freddie Mac purchase certain single-family mortgages in forbearance to keep lending flowing.

  • FHFA allowed Federal Home Loan Banks to accept PPP loans as collateral – April 23

    FHFA announced that the Federal Home Loan Banks can accept Paycheck Protection Program loans as collateral when making loans, called advances, to their member institutions.

  • FHFA ended uncertainty on lump-sum forbearance repayments – April 27

    FHFA clarified borrowers in forbearance with a Fannie Mae or Freddie Mac-backed mortgage are not required to repay the missed payments in one lump sum. Instead, once a hardship has been resolved, the servicer will work with the borrower to:

    • Set up a repayment plan
    • Modify the loan so the borrower’s payments are added to the end of the mortgage
    • Set up a modification that reduces the borrower’s monthly mortgage payment
  • Fed expanded the Municipal Liquidity Facility – April 27

    The revised populations thresholds to make more entities eligible for the Municipal Liquidity Facility announced on April 9. The facility, as revised, will purchase up to $500 billion of short-term notes issued by U.S. states (including the District of Columbia), U.S. counties with a population of at least 500,000 residents, and U.S. cities with a population of at least 250,000 residents.

  • HUD’s Inspector General issued memo on FHA servicers’ forbearance misinformation – April 27

    HUD’s Inspector General assessed what information servicers of mortgage loans that the Federal Housing Administration insures were providing on their public facing websites to borrowers regarding forbearance. Their review of 30 top servicers’ websites, which service approximately 90% of FHA loans, revealed that those websites provided incomplete, inconsistent, dated, and unclear guidance to borrowers related to their forbearance options under the CARES Act.

  • Fed expanded its Main Street Lending Program – April 30

    The Federal Reserve expanded the scope and eligibility of the Main Street Lending Program (announced 4/9) by:

    • Creating a third loan option, with increased risk sharing by lenders for borrowers with greater leverage
    • Lowering the minimum loan size for certain loans to $500,000
    • Expanding the pool of businesses eligible to borrow

March Response Timeline

  • Fed lowered the federal funds rate – March 3

    The Federal Reserve reduced the federal funds rate from a range of 1.5%-1.75% to a range of 1%-1.25% to stimulate economic activity.

  • The Federal Financial Institutions Examination Council updated its pandemic guidance – March 6

    FFIEC, on behalf of its member agencies, issued guidance to remind financial institutions that business continuity plans should address the threat of a pandemic outbreak and its potential impact on critical financial services.

  • Regulators encouraged financial institutions to work with affected borrowers – March 9

    Federal and state financial regulators jointly issued a letter to financial institutions directing them to work constructively with borrowers and other customers impacted by COVID-19. The letter also announced regulatory relief, including flexibility in examinations and inspections, given pandemic-related staffing demands.

  • Federal Housing Finance Agency released a statement on Fannie and Freddie forbearance – March 10

    FHFA released a statement from Director Mark Calabria, noting that Fannie Mae and Freddie Mac had contacted mortgage servicers about loan forbearance options to help borrowers faced with COVID-19 related hardships.

  • Banking regulators issued guidance on assisting affect consumers – March 13

    Banking regulators issued guidance identifying opportunities to work with customers by waiving fees, offering more flexible repayment options, extending payment due dates, increasing credit limits, and increasing ATM withdrawal limits.

  • President Trump declared the COVID-19 outbreak a national emergency – March 13

    President Trump activated emergency powers by issuing national emergency declarations under both the Robert T. Stafford Disaster Relief and Emergency Assistance Act and the National Emergencies Act.

  • Fed employed emergency powers to stabilize the economy – March 15

    The Federal Reserve exhausted its traditional monetary policy tool, lowering the federal funds rate range to 0%-0.25%, referred to as the “zero lower bound.” At the same time, the Federal Reserve developed two other tools to provide economic stimulus—forward guidance and quantitative easing.

  • Federal financial regulators encouraged banks to use the discount window – March 16

    The Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency jointly encouraged banks to borrow from the Fed’s discount window and use intraday credit available through the Fed’s payment systems to meet their liquidity needs.

  • The Department of Veterans Affairs provided guidance to help affected borrowers – March 16

    In Circular 26-20-7, the VA provided guidance on relief to borrowers impacted by COVID-19, encouraging the holders of VA-guaranteed loans to extend forbearance to distressed borrowers, suspend credit bureau reporting on affected loans, and waive late charges. The guidance also directed lenders to have continuity of operation plans in place.

  • Fed revived emergency credit facilities to support the nonbank financial system – March 17

    The Federal Reserve announced it would create:

  • Federal banking regulators encouraged banks to use capital and liquidity buffers to lend – March 17

    The Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency jointly released a statement encouraging banks to use their capital and liquidity buffers to support households and businesses and announcing a technical change to phase in automatic distribution restrictions gradually if a firm’s capital levels decline.

  • Department of Housing and Urban Development halted foreclosures and evictions – March 18

    The Federal Housing Administration published Mortgagee Letter 2020-04, which announced an immediate foreclosure and eviction moratorium for all FHA-insured single-family mortgages for a 60-day period. The move was also summarized in a HUD media advisory.

  • Federal Housing Finance Agency directed Fannie and Freddie to halt foreclosures, evictions – March 18

    FHFA directed Fannie Mae and Freddie Mac to suspend foreclosures and evictions (for homeowners with a Fannie- or Freddie-backed single-family mortgage) for at least 60 days due.

  • VA encouraged its loan holders to halt foreclosures – March 18

    In Circular 26-20-8, the VA issued guidance strongly encouraging holders of loans to veterans to abstain from initiating foreclosure proceedings for at least 60 days.

  • Banking regulators offered favorable Community Reinvestment Act consideration for COVID-19 assistance – March 19

    The Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency jointly announced they would provide favorable Community Reinvestment Act consideration for certain services and activities to help customers and communities affected by the COVID-19 pandemic.

  • Fed created the Money Market Mutual Fund Liquidity Facility - March 19

    The Federal Reserve announced it would create the Money Market Mutual Liquidity Facility to make loans to financial institutions to purchase assets that money market funds are selling to meet redemptions.

  • Department of Agriculture announced foreclosure and eviction moratoria – March 19

    USDA informed lenders that it would be suspending foreclosures on borrowers with Single-Family Housing Direct loans, and on evictions of households in those properties for 60 days.

  • HUD announced foreclosure and eviction moratoria for Tribal/Native Hawaiian loans – March 20

    In Dear Lender Letter 2020-04, HUD announced a foreclosure and eviction moratorium for all loans guaranteed under the Section 184 Indian Home Loan Guarantee program and Section 184A Native Hawaiian Housing Loan Guarantee program for a period of 60 days.

  • USDA updated lenders on continuity of operations planning and new flexibilities – March 20

    USDA issued guidance to stakeholders on adjusting certification requirements to mitigate the potential risk posed by in-person interactions, among other steps intended to update partners of its single-family lending program, Rural Utilities Service, and Rural Business-Cooperative Service.

  • Financial regulators issued joint statement on loan modifications and reporting – March 22

    In a joint statement, federal and state financial regulators clarified that they will not criticize financial institutions for working constructively with borrowers, providing relief on issues such as classifications of loan modifications as troubled debt restructurings.

  • CDC issued guidance to protect people experiencing homelessness from COVID-19 – March 22

    The Centers for Disease Control and Prevention released guidance with key actions that local and state health departments, homelessness service systems, housing authorities, emergency planners, healthcare facilities, and homeless outreach services can take to protect people experiencing homelessness from the spread of COVID-19.

  • Fed announced suite of changes to support the economy – March 23

    The Federal Reserve announced additional steps to support the economy, including:

    • Two new credit facilities to support corporate bond markets—the Primary Market Corporate Credit Facility to purchase newly issued corporate debt and the Secondary Market Corporate Credit Facility to purchase existing corporate debt on secondary markets
    • The Term Asset-Backed Securities Facility to make nonrecourse loans to private investors to purchase ABS backed by student loans, auto loans, credit card loans, SBA-guaranteed loans, and other assets
    • Increased purchases of Treasury securities and mortgage-backed securities, including commercial mortgage-backed securities
    • Expansion of the Money Market Mutual Fund Liquidity Facility (announced 3/19) to include a wider range of securities and the Commercial Paper Funding Facility (announced 3/17) to include high-quality, tax-exempt commercial paper as eligible securities
    • A technical change to “total loss absorbing capacity” buffer requirements to promote lending activity
  • Fannie and Freddie offered multifamily mortgage forbearance, suspended evictions – March 23

    With FHFA’s blessing, Fannie Mae and Freddie Mac announced they will offer mortgage forbearance to multifamily property owners affected by the COVID-19 pandemic—with the condition that they suspend evictions for renters who cannot pay rent due to the pandemic. The forbearance is available to all multifamily properties with a Fannie- or Freddie-backed mortgages and the eviction suspensions are in place for the duration of the time a property owner remains in forbearance.

  • FHFA authorized steps to boost secondary mortgage market liquidity – March 23

    FHFA authorized Fannie Mae and Freddie Mac to enter into additional dollar roll transactions—a way to provide mortgage-backed securities investors with short-term financing—in an effort to boost liquidity in the secondary mortgage market.

  • FHFA directed Fannie and Freddie to grant appraisal and employment verification flexibility – March 23

    FHFA directed Fannie Mae and Freddie Mac to provide alternative flexibilities to satisfy appraisal requirements and employment verification requirements through May 17, 2020. Fannie Mae and Freddie Mac issued the attendant guidance in Lender Letter 2020-03, Lender Letter 2020-04, and Bulletin 2020-5.

  • Fed outlined changes to its supervisory approach – March 24

    The Federal Reserve provided additional information to financial institutions on adjustments in its supervisory approach because of the COVID-19 pandemic, such as examination activities reductions and additional time for compliance with non-critical supervisory findings.

  • USDA’s Rural Development added to its guidance on affected borrowers and grantees – March 25

    USDA’s rural development office announced steps to help borrowers in their housing and utility credit programs, including a 60-day moratorium on foreclosures and evictions for single-family direct loans and loan guarantees, loan forbearance, and regulatory flexibilities for Section 515 multifamily properties.

  • Fannie and Freddie updated their servicing requirements – March 25

    In Lender Letter 2020-02, Lender Letter 2020-05, Bulletin 2020-6, Bulletin 2020-7, Fannie Mae and Freddie Mac updated their servicing requirements and relief related to the COVID-19 crisis, for example, announcing a new payment deferral loss mitigation option, providing temporary flexibility on property inspection and preservation requirements, and adding a specified delinquency code for borrowers experiencing COVID-19-related hardships.

  • Federal financial regulators encouraged small-dollar loans to consumers, small businesses – March 26

    The Federal Reserve, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, and National Credit Union Administration issued a joint statement encouraging financial institutions to offer prudent small-dollar loans to consumers and small businesses in response to COVID-19.

  • Fed offered regulatory reporting relief to small financial institutions – March 26

    Recognizing that small financial institutions face changing staffing priorities and disruptions from COVID-19, the Federal Reserve announced it would not take action against them for failing to meet certain regulatory reporting requirements.

  • Financial Stability Oversight Council formed task force on nonbank mortgage servicers – March 26

    The Financial Stability Oversight Council, a group of financial regulators tasked with identifying and addressing threats to the financial system, announced it would form a task force to monitor the activities of nonbank mortgage servicers.

  • CFPB provided Home Mortgage Disclosure Act reporting flexibility – March 26

    The Consumer Financial Protection Bureau issued a policy statement announcing it would not cite financial institutions for failing to report data required quarterly by the Home Mortgage Disclosure Act, a step intended to provide lenders with flexibility and reduce their administrative burden, allowing them to focus attention on providing consumers with COVID-19 hardships assistance.

  • VA issued origination and appraisal guidance – March 27

    In Circular 26-20-10 and Circular 26-20-11, the VA provided guidance to lenders on temporary measures regarding loan origination, closing, and guaranty, as well as valuation and appraisal practices during the COVID-19 pandemic.

  • The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law – March 27

    The CARES Act made significant resources available to help struggling families stay at home through this public health crisis and aid state and local governments facing serious fiscal headwinds. In particular, the bill provided:

    • Direct payments to households that may experience financial hardship
    • Funding for a broad liquidity facility that could be tapped by mortgage market participants
    • Single-family and multifamily/commercial forbearance, foreclosure, and eviction provisions
    • Limits on adverse credit reporting during the COVID-19 crisis
    • $17.4 billion in emergency supplemental appropriations to HUD, including $5 billion for community development block grants and $4 billion in homeless assistance grants
  • HUD provided guidance on employment and appraisal requirements - March 27

    HUD released Mortgagee Letter 2020-05 detailing flexibilities associated with re-verification of income and appraisals for Federal Housing Administration mortgage insurance.

  • Ginnie Mae announced new liquidity facility – March 27

    Ginnie Mae provided notice of its intention to establish a liquidity facility to support mortgage servicers. In the event of large-scale borrower forbearance due to COVID-19 impacts, Ginnie Mae servicers must continue to advance payments to investors of mortgage-backed securities, regardless of whether they receive monthly payments from borrowers. The announced liquidity facility will give servicers greater access to liquidity to advance payments until they are ultimately reimbursed. Ginnie also announced that liquidity assistance for single-family servicers will be followed by options for multifamily and reverse mortgage servicers.

  • USDA granted lenders new flexibilities – March 27

    USDA announced to lenders temporary exceptions pertaining to appraisals, repair inspections, and income verification for the Single-Family Housing Guaranteed Loan Program due to the COVID-19 pandemic, in effect for a period of 60-days.

  • HUD issued FAQs for housing authorities – March 30

    HUD issued “COVID-19 FAQs for Public Housing Agencies,” including guidance on property inspections, remote public meetings, information sharing, and regulatory waivers.

  • FHFA authorized loan processing flexibilities for Fannie and Freddie – March 31

    FHFA authorized Fannie Mae and Freddie Mac to provide additional flexibilities to reduce the need for person-to-person contact in the loan origination process, such as allowing desktop appraisals and expanding the use of remote online notarizations. Details are found in updates to Lender Letter 2020-03, Lender Letter 2020-04, and Bulletin 2020-8.

  • USDA allowed loan payment deferrals – March 31

    USDA granted lenders a temporary exception to offer payment deferrals for its guaranteed loan programs due to the pandemic’s impact. Until September 30, 2020, lenders are allowed to offer 180-day loan payment deferrals without prior approval for Business and Industry Loan Guarantees, Rural Energy for America Program Loan Guarantees, Community Facilities Loan Guarantees, and Water and Waste Disposal Loan Guarantees.

  • HUD posted FAQs on disaster recovery grants and COVID-19 – March 31

    HUD released a set of frequently asked questions to provide information to Community Development Block Grant Disaster Recovery, National Disaster Resilience, and Mitigation grantees on flexibilities with timelines, eligible activities, and citizen participation announced in response to COVID-19.

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