Regulatory Impact Analysis: Emergency Homeowners’ Loan Program

Michael K. Hollar, U.S. Department of Housing and Urban Development

Impact

A regulatory impact analysis must accompany every economically significant federal rule or regulation. The Office of Policy Development and Research performs this analysis for all U.S. Department of Housing and Urban Development rules. An impact analysis is a forecast of the annual benefits and costs accruing to all parties, including the taxpayers, from a given regulation. Modeling these benefits and costs involves use of past research findings, application of economic principles, empirical investigation, and professional judgment.

This article reflects the views of the authors and does not necessarily reflect the views of the U.S. Department of Housing and Urban Development.

The Emergency Homeowners’ Loan Program (EHLP), as enacted in the Dodd-Frank Wall Street Reform and Consumer Protection Act, allows the U.S. Department of Housing and Urban Development (HUD) to provide a maximum of $50,000 to homeowners who are 90 or more days delinquent on their mortgages due to a 15-percent or greater reduction in household income and face the threat of foreclosure. Reasons for the reduction of income are limited to involuntary unemployment, involuntary underemployment, and medical conditions. EHLP participants must come from households that earned no more than 120 percent of Area Median Income (AMI) before the decrease in income. EHLP provides assistance through a 5-year, no-interest loan, with loan repayment beginning after program assistance ends. Payments cease after 24 months or $50,000, whichever comes first, which allows up to 7 years from loan disbursement to full repayment. Finally, EHLP assistance is limited to homeowners in Puerto Rico and in the 32 states that are not assisted by the Department of the Treasury’s Innovation Fund for Hardest Hit Housing Markets program.