Chenoa Fund, offered by CBC Mortgage Agency, provides 1st and 2nd mortgage products on a national level to home buyers who need assistance with their down payment.
HUD's new rules on Down Payment is the top story of 2019 according to HousingWire. HUD's mortgagee letter 2019-06 took effect April 18th of this year. This was followed by a flurry of legal activity with CBC Mortgage Agency suing HUD over the rule and the court issuing a 90-day stay to hear the arguments against the Mortgagee letter. This stay remains in effect until July 23rd, but it is anticipated that the court will make a final decision before that time. HUD is obligated to insure any case number issued prior to July 23rd. The final promulgation issued by the court could effect this date indefinitely.
At issue here is how HUD creates new mortgage regulations for the industry. For a quick primer on the subject, here is a wikipedia article on The Administrative Procedures Act of 1946. Simply stated, Congress delegates certain legal powers to executive branch agencies and they are required to follow certain procedures to ensure that executive-branch regulation has a check and balance. Many of the laws that we live by in the United States, especially business-related ones, come to us through the application of this rule. The second basic purpose of this law is that the public will have participation in the rule-making process, and this is typically done through a public-comment period. This mortgagee letter had no comment period, and HUD issued the rule quite suddenly without allowing input from various stakeholders. This is especially concerning considering the social-proof that HousingWire has outlined here over the ruling. If this Mortgagee letter is HW's number one story, it seems likely there is a general public interest in this issue and its eventual outcome.
CBC Mortgage Agency is committed to increasing home ownership throughout the United States, and we see home ownership as a critical component to help eliminate, in particular, minority-poverty. Additionally, we create competitive options for home buyers across the United States which facilitate a healthy, demand-driven market increasing affordibility and access. We are anxiously awaiting the final ruling on this issue, and we expect a positive outcome sometime in mid-July. If you have questions about our program, please feel free to email me at shawn.king@chenoafund.org.
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