JOver the past few months, a number of legal developments have impacted real estate lending operations and compliance. For example, effective January 1, 2025, California Assembly Bill (AB) 2424 imposes new foreclosure and disclosure-related requirements for certain loans secured by one- to four-family residential real properties. In March 2025, HUD announced that, effective May 25, 2025, the Federal Housing Administration (FHA) will no longer provide FHA-insured mortgages to non-permanent residents, including those without legal U.S. residency. This change means that both undocumented immigrants and documented non-immigrants are no longer eligible for FHA mortgages. Previously, non-permanent residents could qualify with certain documentation, but that option has been eliminated. Separately, there have been a number of new appraisal-related developments. For example, in March 2025, HUD revoked its prior Reconsideration of Value policy applicable to FHA mortgages. Further, in April 2025, the prudential regulators announced that, as a result of the January 2025 wildfires, and subject to certain limitations, they were exempting certain real estate lending transactions located in Los Angeles County from FIRREA Title IX's appraisal-related requirements until January 8, 2028.
Join us for the May BCG Monthly Telephone Briefing on May 16, 2025, where we will discuss these and other recent real estate lending-related developments.
Handout to be posted Thursday May 15th.