“Streamlined refinancing also creates efficiencies that are valuable in high refinance volume environments to allow for larger pipelines to refinance more eligible borrowers. In a low-rate environment, streamlined refinancing helps borrowers at risk of delinquency and default by lowering their monthly payments.”

MBA also prompted the bureau to prioritize reforms that will lower manufacturing costs and reduce regulatory restrictions on loan originators.

“We encourage the bureau to focus on areas where their regulations add costs to the loan manufacturing or servicing process, particularly with diffuse or unclear consumer benefits,” Mills said. “The bureau should also make changes to the Loan Originator Compensation (LO Comp) rule to help consumers and reduce regulatory burden. The LO Comp rule still places strict limits on certain practices that would result in lower consumer costs that should be rethought in some contexts.”

As for forbearances, the MBA is advocating for a “clear and flexible” loss mitigation regulatory framework guided by the lessons learned from the pandemic.

“Industry and policymakers should continue to study the impact of the COVID-19 pandemic on the market and consumers before completely endorsing the repayment flexibilities of the pandemic, particularly self-attestations of hardships and extended terms for forbearance,” it was stated. “The COVID-19 pandemic was a unique event that saw unprecedented national economic support and stimulus in response to a public health crisis. Accordingly, the lessons learned by the bureau from the crisis should reflect that critical context and not assume the same circumstances in the future.”