On the Hill is NAMB's bi-weekly read on what's happening in Washington and why it matters to mortgage brokers.
Each issue cuts through the noise to bring you the federal policy, legislation, and regulatory moves shaping your business, along with the context and action items you need to stay ahead.
Brought to you by the National Association of Mortgage Brokers, the voice of the broker community since 1973. |
The White House put its name on a mortgage cost executive order, Treasury started writing the rules for the new investor limits, and the appraisal format change hits on Monday. The credit report overhaul is still a promise rather than a policy. Here's what brokers need to know. |
LEAD STORY: Executive order targets mortgage insurance and title costs, and the details are still arriving |
President Trump signed Executive Order 14438 on October 22, as we told you in our special edition that day. Now that more of the text is being reported, a few specifics are worth knowing. The order tells FHFA to build a pilot that cancels mortgage insurance on Fannie Mae and Freddie Mac loans without the borrower having to ask, using automated home value estimates to find loans that have enough equity. Servicers would have to notify eligible borrowers quickly, with less paperwork and fewer appraisals. It also tells FHFA to turn the title insurance waiver pilot into an ongoing nationwide program. Reporting on the order says the FHFA Director could allow automated title review in place of a lender's title policy on eligible refinances, consider lifting the 80% loan-to-value cap, drop the geographic limits, and trim loan-level price adjustments, with the savings required to reach borrowers. The order also creates a manufactured housing task force, due to report to the President in 180 days, and tells USDA and VA to lower rates on the loans they make directly.
Why it matters: this is direction to the agencies, not finished policy. The order sets no deadlines for the FHFA programs, and the full text has not reached us yet. Our special edition noted that LLPA changes were only rumored; the later reporting says the title program section covers them, so we are treating that as likely but unconfirmed until we read the order itself. Keep your pricing, disclosures, and borrower advice as they are until FHFA issues guidance. In the meantime, start sorting your past clients by equity and mortgage insurance, because those are the files that could benefit first.
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Tri-merge: still "considering," still no announcement
The credit report overhaul remains unofficial. On October 19, ABA Banking Journal reported that Director Bill Pulte said on X that FHFA is considering requiring only one or two credit reports on loans Fannie Mae and Freddie Mac buy, with no details and no date. That is a softer statement than the bi-merge plan Bloomberg described on October 1, and we have not found a formal FHFA announcement. Pulte also said decisions on loan-level price adjustments are expected before year end. Fannie and Freddie still require three reports, and so does FHA. Do not change your credit workflow until there is a written policy with an effective date.
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Treasury: conservatorship exit is not coming soon
On October 20, Treasury Secretary Scott Bessent said the government is not about to loosen its hold on Fannie Mae and Freddie Mac. He questioned whether homeowners would gain anything from a change in the companies' ownership structure and said the test for any decision is that mortgage spreads must not rise. For brokers, the practical read is that the GSE rules you work under are likely to keep coming from FHFA directive rather than from a restructuring.
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UAD 3.6 mandate starts Monday, November 2
The new appraisal format is required for GSE loans starting Monday. Lenders that are not ready can use a one-time exception to keep submitting the older format through May 19, 2027, but the exception goes to lenders, not brokers, so your wholesale partners may be on different formats. NAMB President Mike Farrell told Mortgage Professional America that brokers should disclose appraisal costs based on the higher 3.6 outcome, in case that is what the file ends up needing. He cited one quote of $555 for the old format against $850 for the new one, expects added turn time of three to five days, and noted industry groups expect roughly a quarter of field appraisers to leave rather than adopt the new format. Tell your agents to build longer contract periods than the usual 30 days. Loans with older-format appraisals also lose some appraisal rep-and-warrant relief on March 1, 2027.
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Condo rules: no change, January 4 still on the calendar
We found no new FHFA action on Fannie Mae Lender Letter LL-2026-03 this fortnight. Limited Review was retired on August 3, and the HOA reserve requirement still moves from 10% to 15% of the annual budget on January 4, 2027. An FHFA spokesperson has said Fannie and Freddie are implementing on time, and the agency has not acted on NAMB's June 15 request for a delay of at least 12 months. NAMB's white paper, state-by-state analysis, and social media kit remain available at namb.org/condo-financing.
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Treasury proposes its first rule on the investor limits in the ROAD to Housing Act
On October 22, Treasury proposed a rule implementing the part of the 21st Century ROAD to Housing Act that limits large institutional investors from buying single-family homes. Starting January 7, 2027, investors with control over 350 or more single-family homes generally could not buy more, unless the purchase falls into an excepted category such as build-to-rent. The proposal also covers renovate-to-rent safe harbors, how penalties are calculated, and what counts as being "in the business" of investing. Comments are due 30 days after Federal Register publication, so check the publication date. Why brokers should care: the rule decides how much room investors have to compete with your first-time and owner-occupant buyers, and it is the first of many ROAD Act rulemakings.
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VA home loan fees: H.R. 9237 still needs your voice
The most recent reporting we found shows no new action on H.R. 9237, the Take Care of America's Veterans Act. Section 104 would raise the VA IRRRL funding fee from 0.50% to 1.42% and double the assumption fee from 0.50% to 1.00%, to help pay for other veteran benefits. The House has not passed it. A motion to recommit failed 210 to 211 on July 16 and further consideration was postponed. NAMB supports the benefits for combat-injured veterans and backs the standalone Major Richard Star Act (H.R. 2102 / S. 1032) as a way to pay for them without raising costs on veteran borrowers. With the midterms on November 3, a lame duck session could bring the bill back, so the call to action stays open.
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H.R. 5508: no movement
H.R. 5508, the Mortgage Insurance Freedom Act sponsored by Rep. Gregory Meeks, has had no action since it was referred to the House Financial Services Committee in September 2025. With the executive order now pushing mortgage insurance cancellation through FHFA, it is worth watching whether the bill picks up attention.
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FHA: nothing new, January 1 is the date to know
We found no new FHA policy this fortnight. The alternative credit score rules in Mortgagee Letter 2026-11 still apply to case numbers assigned on or after January 1, 2027, and FHA still requires three credit reports. Ask your FHA lenders which score models they will accept on January 1.
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CFPB: Johnson nomination still waiting
The Senate Banking Committee advanced Brian Johnson's nomination to lead the CFPB on September 17, by a 13 to 11 party-line vote. We have not found a report of a full Senate vote since. LO compensation and RESPA servicing reform remain the rulemakings to watch.
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30-year fixed: 7.32% (Freddie Mac PMMS, October 22), down from 7.40% the week before and up from 6.19% a year ago.
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15-year fixed: 6.68% (October 22), down from 6.71% the week before.
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What your association is focused on:
- Executive order follow-through: NAMB is engaged with FHFA and the agencies and will push for implementation that lowers borrower costs while protecting the broker channel. Share what you are seeing with GovernmentAffairs@namb.org.
- Pricing and affordability: NAMB continues to press for relief on loan-level price adjustments.
- Appraisals: NAMB is helping brokers navigate UAD 3.6 and the cost and timing questions it raises.
- Veterans' lending: the H.R. 9237 call to action is live at namb.org/call-to-action.
- Ongoing: LO comp reform, flood insurance improvements, credit report cost relief, and expanded affordable housing access remain 2026 priorities.
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Nov 2, 2026: GSE UAD 3.6 mandate takes effect.
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Nov 3, 2026: Midterm elections.
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Any day: FHFA guidance on the executive order, a decision on credit reports, and LLPA changes expected before year end.
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Dec 11, 2026: next federal funding deadline.
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Jan 1, 2027: FHA alternative credit scores apply to new case numbers.
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Jan 4, 2027: condo HOA reserve requirement rises from 10% to 15%.
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Jan 7, 2027: proposed start date for the Treasury investor purchase limits.
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Mar 1, 2027: UAD 2.6 exceptions lose some rep-and-warrant relief.
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May 20, 2027: mandatory UAD 3.6 use for all new submissions.
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