October 11, 2022 — Letter

The Housing Policy Council and the National Consumer Law Center write to provide a joint update on the groups’ recommendations regarding the Servicing Defect Taxonomy that FHA is developing. Since submitting initial recommendations, HPC and NCLC have worked closely together in an effort to reach alignment on a number of issues where those previous recommendations diverged.

We have attached a revised version of HPC’s Taxonomy (the “Revised HPC Proposal”). Although areas of
divergence remain, HPC and NCLC strongly encourage FHA to review this Revised HPC Proposal in
connection with the issuance of a Taxonomy. We again note that it is most important that the
Taxonomy contain sufficient detail, clarity, and certainty to promote full engagement in the FHA
Program. Importantly, this Revised HPC Proposal reflects the following specific recommendations on
which HPC and NCLC jointly agree: