Warehouse Lending & Other Loan Funding Mechanisms

SIFMA provides comments to the U.S. Department of Housing and Urban Development (HUD) on warehouse lending and other loan funding mechanisms, Federal Register 75 F.R. 71724.  HUD is considering the issuance of guidance under the Real Estate Settlement Procedures Act of 1974, as amended (RESPA) to address changes in warehouse lending and other financing mechanisms used to fund federally related mortgage loans that have occurred since HUD issued regulations specifically related to this area over 15 years ago. SIFMA believes it is important to ensure that providers of traditional, bona fide funding mechanisms for non-depository mortgage lenders are not recharacterized as mortgage lenders under RESPA.