NCLC submitted comments to support HUD’s decision to promulgate regulations that establish the necessary framework for a successful default servicing program and that supplement the guidance established by the Real Estate Settlement Procedures Act (RESPA). However, NCLC urges HUD to eliminate specific details of loss mitigation eligibility provisions from the regulation because flexibility is necessary to adapt to any volatility that the economy and the mortgage market may face. Instead, as with FHA’s use of Mortgagee Letters, HUD should use Public and Indian Housing (PIH) Notices to issue specific eligibility requirements for loss mitigation because issuing PIH Notice does not require a full regulatory process and gives the agency the ability to more quickly adapt its loss mitigation system to the mortgage market.