Promoting Access to Mortgage Credit

3/13/2026

Action Summary

  • Purpose and Policy Objectives: Improve access and affordability of mortgage credit by reducing regulatory burdens that have limited community and smaller banks from lending effectively, particularly affecting rural, low-, and moderate-income households.
  • Origination and ATR/QM Reform: Directs the CFPB to amend Regulation Z and related rules to tailor ATR and Qualified Mortgage requirements for smaller banks; includes proposals to streamline TRID timing, adjust fee caps, modernize digital processes, and simplify refinancing and underwriting practices.
  • Home Mortgage Disclosure Modernization: Instructs the CFPB to propose changes to Regulation C that raise asset thresholds for HMDA exemptions, exclude certain inquiries, and ensure privacy while reducing software and training burdens.
  • Capital and Liquidity Alignment: Calls for revising capital regulations and risk weights for mortgage-related exposures, modernizing collateral valuation between the Federal Reserve and FHLBs, and establishing targeted liquidity and affordable housing programs, with a report on national housing finance efficiency due within 120 days.
  • Construction and Housing Supply: Recommends revising supervisory guidance to clearly differentiate one-to four-family residential development from commercial real estate, thereby supporting responsible construction lending by community banks.
  • Appraisal Modernization: Aims to expand the use of alternative valuation models, desktop/hybrid appraisals, and AI tools; simplify appraiser qualifications; reduce requirements for low-risk transactions; and align appraisal standards between FHA and VA programs.
  • Digital Mortgage Modernization: Proposes eliminating wet-signature requirements and standardizing the use of electronic signatures, e-notes, and remote online notarization to promote digital mortgage practices.
  • Servicing and Supervisory Certainty: Seeks to align supervisory expectations to better support portfolio mortgage servicing by community banks, extend cure‑first standards, simplify loss mitigation, and provide exemptions from complex servicing rules.
  • Enforcement and Licensing Adjustments: Directs agencies to develop policies that reduce civil penalties for good-faith technical compliance errors and to eliminate duplicative licensing requirements for mortgage loan officers at smaller banks.
  • General Provisions: Clarifies that the order does not impair agency authority or create enforceable rights, and that implementation is subject to applicable law and funding availability.

Risks & Considerations

  • The Executive Order aims to promote access to mortgage credit, which could lead to increased opportunities for community banks. However, this shift may create challenges for larger financial institutions, potentially leading to market instability.
  • Reducing regulatory burdens on community banks might lead to increased risk if these institutions engage in lending practices that prioritize speed over thoroughness. This could result in higher default rates and negatively impact borrowers, particularly low- and moderate-income households.
  • Changes in the mortgage lending landscape will require Vanderbilt University to be aware of potential shifts in housing market dynamics, which could affect the demographics and financial stability of prospective students.
  • The emphasis on digital mortgage modernization may necessitate that Vanderbilt adapt its financial aid and housing support services to meet the evolving needs of students navigating these new systems.

Impacted Programs

  • Vanderbilt’s Financial Aid Office may need to adjust its strategies to accommodate students who may face different challenges in securing mortgage financing, particularly if they come from low- and moderate-income backgrounds.
  • Peabody College of Education and Human Development could see increased demand for research on housing access and affordability, aligning its efforts with community needs.
  • Vanderbilt’s Office of Community Engagement might play a crucial role in supporting initiatives aimed at improving access to housing, thereby enhancing its community partnerships and outreach efforts.
  • The School of Business may have opportunities to engage in research and training related to the changing mortgage landscape, potentially leading to partnerships with financial institutions.

Financial Impact

  • As community banks gain a foothold in mortgage lending, there could be increased competition for student housing financing, impacting rental prices and availability around campus.
  • Vanderbilt may experience fluctuations in student demographics as changes in mortgage accessibility influence where prospective students choose to live and study.
  • The potential for increased mortgage lending could lead to economic growth in the surrounding community, positively impacting Vanderbilt’s local partnerships and funding opportunities.
  • Changes in housing finance regulations might affect the financial aid strategies that Vanderbilt employs, necessitating a reevaluation of how it allocates resources for student support.

Relevance Score: 3 (The order presents moderate risks typically involving compliance or ethics that the university needs to address.)

Key Actions

  • Vanderbilt’s Office of Federal Relations should monitor the implications of the executive order on mortgage credit access, particularly for community banks. Engaging with banking partners and local financial institutions can help understand the impact on borrowers and adjust financial aid or housing programs accordingly.
  • The Department of Economics should conduct research on the effects of reduced regulatory burdens on mortgage lending, focusing on how these changes affect low- and moderate-income households. This analysis can provide insights to inform Vanderbilt’s community outreach and support programs.
  • Vanderbilt’s Real Estate Program should consider collaborating with local banks to develop innovative mortgage products aimed at increasing access for underserved populations. This could enhance the university’s role in promoting equitable housing solutions.
  • The Department of Public Policy should analyze the potential impacts of appraisal modernization on housing accessibility, and advocate for policies that ensure fair and affordable housing for diverse communities.
  • Vanderbilt’s Research Centers can explore the effects of digital mortgage modernization on home buying trends, particularly for first-time buyers. Insights from this research can guide policy recommendations to improve housing access.

Opportunities

  • The executive order presents an opportunity for Vanderbilt’s Public Policy Program to lead discussions on housing finance reform, positioning the university as a thought leader in the intersection of housing policy and economic development.
  • Vanderbilt can enhance its community engagement by partnering with local organizations to provide educational workshops on mortgage access, helping to demystify the home-buying process for low-income families.
  • There is potential for Vanderbilt’s School of Law to offer pro bono legal assistance to families navigating the mortgage process, thereby increasing access to home ownership and aligning with the university’s commitment to social justice.
  • By leveraging the changes in appraisal regulations, Vanderbilt can support initiatives that promote affordable housing developments in Nashville, helping to address local housing shortages.
  • The university can also explore opportunities for research funding related to the impacts of mortgage credit access on community development and economic stability, tapping into federal resources made available through the executive order.

Relevance Score: 4 (The order presents the potential for major process changes required for Vanderbilt’s programs due to impacts on housing access and financial aid strategies.)

Average Relevance Score: 3.6

Timeline for Implementation

Within 120 days of March 13, 2026: The Director of the FHFA, in consultation with other relevant officials, must submit a report on the efficiency of national housing finance markets.

Relevance Score: 2

Impacted Government Organizations

  • Consumer Financial Protection Bureau (CFPB): Responsible for proposing amendments to Regulation Z and modernizing mortgage-related consumer disclosure and servicing rules.
  • Federal Reserve (Vice Chairman for Supervision/Board of Governors): Involved in revising supervisory guidance on mortgage lending, capital regulations, and facilitating liquidity measures.
  • National Credit Union Administration (NCUA) Board: Tasked with revising supervisory guidance and evaluating mortgage lending practices for credit unions.
  • Federal Deposit Insurance Corporation (FDIC): Engaged in modernizing mortgage underwriting, supervisory guidance, and eliminating duplicative licensing requirements.
  • Office of the Comptroller of the Currency (Comptroller of the Currency): To consider updates to risk management standards and supervisory evaluations in mortgage banking.
  • Federal Housing Finance Agency (FHFA): Charged with modernizing collateral valuation, enhancing FHLB liquidity programs, and improving digital mortgage processes.
  • Department of Housing and Urban Development (HUD): Involved in modernizing appraisal regulations and aligning appraisal standards for residential and VA lending programs.
  • Department of Veterans Affairs (VA): To consider alignment of appraisal standards with HUD for risk-comparable loan products.
  • Department of Agriculture: Tasked with promoting digital mortgage standards and eliminating unnecessary wet‑signature requirements in mortgage processes.
  • Office of Management and Budget (OMB): Mentioned in general provisions regarding consultation on efficiency and oversight in housing finance markets.
  • Department of the Treasury: Responsible for bearing the costs for publishing the order, indicating financial oversight involvement.

Relevance Score: 4 (Between 11-15 agencies are impacted, indicating significant regulatory reach across multiple financial and housing-related agencies.)

Responsible Officials

  • Director of the Consumer Financial Protection Bureau (CFPB) – Charged with considering amendments to Regulation Z, modernizing HMDA data collection, and issuing supervisory guidance related to mortgage underwriting and servicing.
  • Vice Chairman for Supervision of the Federal Reserve System – Tasked with revising supervisory guidance, capital and liquidity alignment measures, enforcement policies, and facilitating digital mortgage modernizations.
  • Chairman of the National Credit Union Administration (NCUA) Board – Responsible for evaluating and revising supervisory policies and capital regulations as related to mortgage activity and credit risk management.
  • Chairperson of the Board of Directors of the Federal Deposit Insurance Corporation (FDIC) – Involved in examining and updating supervisory guidance, capital requirements, and enforcement practices in the mortgage sector.
  • Comptroller of the Currency – Expected to participate in reviewing and revising supervisory practices and regulatory frameworks concerning mortgage lending and servicing.
  • Director of the Federal Housing Finance Agency (FHFA) – Charged with modernizing collateral processes, expanding liquidity programs, and reporting on national housing finance market efficiencies.
  • Secretary of Housing and Urban Development (HUD) – Responsible for considering appraisal modernization, digital mortgage processes, and aligning housing finance supervisory expectations.
  • Secretary of Veterans Affairs (VA) – Involved in aligning appraisal standards with HUD for comparable risk in home loan programs.
  • Secretary of Agriculture – Expected to consider and promote digital mortgage modernization initiatives in coordination with other federal agencies.

Relevance Score: 5 (Directives impact high-level regulatory and Cabinet officials across multiple key federal agencies with significant, broad financial sector implications.)