The groups strongly support HUD’s plan to issue guidance on ROVs, but the proposed Mortgagee Letter needs substantial improvement. It should be revised to provide clear, strong standards for mortgagees and a uniform ROV disclosure for borrowers.
Comments submitted by: Consumer Action, Long Island Housing Services, Inc., Mountain State Justice, Inc., NAACP Legal Defense and Educational Fund, Inc. (LDF), National Coalition for Asian Pacific American Community Development (National CAPACD), National Community Reinvestment Coalition, National Community Stabilization Trust, National Consumer Law Center (on behalf of our low-income clients), National Fair Housing Alliance, New Jersey Institute for Social Justice, UnidosUS, and Woodstock Institute