July 5, 2022 — Letter

Center for Responsible Lending, National Consumer Law Center (on behalf of its low-income clients), National Fair Housing Alliance, and National Housing Conference share reactions to the Defect Taxonomy straw proposal that the Housing Policy Council (HPC) sent to HUD on May 12, 2022.

We think an effective defect taxonomy can be a critical tool in clarifying HUD’s expectations to servicers and thereby improving borrower outcomes. We urge HUD to convene further conversations on the taxonomy.

Below we provide our topline reactions to HPC’s proposal.