The Federal Housing Finance Agency wants to increase the guarantee fees (G-fees) paid by homeowners for loans originated in five states that the agency characterizes as having excessively high foreclosure costs. This plan has elicited letters of strong opposition from housing and consumer advocates (including AFR), members of Congress, legal and policy experts, Attorneys General, state legislators, and industry groups concerned about the state of the housing market.

These critics argue, among other things, that the proposal would punish borrowers in states with consumer protections designed to prevent unnecessary foreclosures, and pressure states to either do away with such protections or not adopt them in the first place; that it oversteps the bounds of the FHFA’s authority and mission; that it ignores a crucial driver of delay in the foreclosure process, which is the failure of mortgage servicers to follow required laws and procedures; and that it is based on a deeply flawed analysis of  costs – one  that, among many problems, ignores the ability of consumer protection measures to reduce costs by preventing foreclosures.

These individuals and organizations have thus far submitted letters to the FHFA:

Americans for Financial Reform

Adam Levitin (Harvard Law School/Georgetown University Law Center), Alan White (CUNY School of Law), Elizabeth Renuart (Albany Law School)

Alan White (CUNY School of Law)

Attorneys General of Illinois, Connecticut, and New York

Brennan Center for Justice

Center for American Progress and Co-Signers

Community and Faith Based Organizations

Connecticut Attorney General

Connecticut Congressional Delegation

Connecticut Fair Housing Center, on behalf of attorneys representing CT lenders & homeowners in foreclosure procedures

Eighteen Senators and House Members from New York State

Institute for Policy Integrity (NYU Law School)

Legal Services of New Jersey

Maine Groups

National Association of Consumer Advocates

National Association of Realtors

National Council of State Housing Agencies

New York Mortgage Coalition

New York State Assembly Leaders

New York State Consumer Fraud and Protection Bureau (A.G.’s Office)

New Yorkers for Responsible Lending

Senators Blumenthal, Menendez, Lautenberg, Schumer, Gillibrand, Lieberman, & Nelson 


Press coverage:

Albany Times Union

New York Post