MBA Letter to FHFA on Title Acceptance Pilot

2024 Comment Letters Government Lending Government Servicing Policy Issue Residential
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The Mortgage Bankers Association (MBA) writes to express our deep concerns regarding the Federal Housing Finance Agency’s (FHFA) recent announcement of the approval of a “Title Acceptance Pilot” which aims to reduce costs for a small group of borrowers by allowing Fannie Mae to remove existing requirements that a lender’s title insurance policy or Attorney Opinion Letter (AOL) be obtained for certain transactions. It is particularly concerning that to our knowledge this pilot program has not gone through the proper procedures required by FHFA for new products and activities and appears to violate “bright line” principles by encroaching into the primary mortgage market. 

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