CUNA appreciates the pandemic response from the Federal Housing Finance Agency and encourages it to ensure there is consistency between their policies and directives of Congress. CUNA submitted a comment letter to a House Financial Services subcommittee hearing on mortgage servicers and the implementation of the CARES Act with several recommendations on helping credit unions serve members and small businesses across the country.

“From the outset of the COVID-19 pandemic, credit unions have worked to ensure that their members, employees and volunteers remain safe and healthy, and that they are able to continue providing access to financial services to their members [as] 95% of credit unions are offering loan forbearances; more than 85% are waiving fees; and 80% have created new loan products to meet members’ pressing needs,” the letter reads. “Still, many Americans have experienced extreme hardship and job loss as a result of the pandemic. Economic experts anticipate a host of foreclosures and evictions in the months ahead.”

Highlights of the letter include:

• CUNA supports the Emergency Rental Assistance and Rental Market Stabilization Act of 2020 (H.R. 6820), which would establish a $100 billion emergency rental assistance program directed to the states, as well as S. 3620, which would establish a $75 billion Housing Assistance Fund;
• Congress should create a financing program, or liquidity facility, for mortgage servicers in need of assistance to preserve their ability to respond to unprecedented levels of payment forbearance required by borrowers affected by COVID-19;
• The deadline for the Troubled Debt Restructuring exemption crated by the CARES Act should be extended past the currently scheduled expiration (end of 2020 or 60 days after the end of the national emergency, whichever is sooner) to at least the end of 2021;
• Congress should extend the COVID-19 related enhancements to NCUA’s Central Liquidity Facility through 2021 and increase the borrowing authority multiplier from 16 to 25; and
• Congress should urge the FHFA to issue guidance and additional resources addressing the treatment of escrow, private mortgage insurance, credit life, credit disability and interest during the period of loan deferment and after the deferment concludes.