The Washington Report

On September 1, 2026, NAR submitted comments to the Federal Housing Administration (FHA) supporting the agency's draft policy establishing the Reinstatement Advance Payment (RAP) demonstration. As NAR previously reported, RAP would give servicers a voluntary alternative to securing partial claims through a separately recorded subordinate mortgage. The past-due amount would instead be carried as a non-interest-bearing balance under the existing FHA-insured mortgage. The borrower would still repay it, but there would be no separate lien to locate and release at closing.

NAR's letter explains that the draft policy responds directly to a problem NAR members have raised for years. Because partial claim liens rarely appear on a borrower's monthly statement, sellers often do not learn they exist until a title search turns them up, sometimes days before settlement. The resulting scramble for a payoff and release delays closings, and in some cases the outstanding balance substantially reduces or eliminates the seller's expected proceeds and puts the sale at risk. NAR told FHA that RAP would offer a more transparent way to administer these obligations without changing what the borrower owes.

NAR also identified several areas where FHA could strengthen the demonstration. Because participation is voluntary, NAR encouraged FHA to monitor servicer uptake and address any barriers to use, since limited participation would leave many borrowers facing the same lien-related closing problems the demonstration is meant to solve. NAR also urged FHA to require that the outstanding RAP balance appear as a clearly labeled, standard line item on every periodic statement rather than at servicer discretion, so that borrowers know what they owe and can obtain an accurate payoff before a sale or refinance is underway. Finally, NAR asked FHA to weigh borrower affordability as it develops repayment terms. A RAP balance that comes due as a lump sum when the FHA-insured mortgage matures functions much like a balloon payment, a structure NAR has long viewed as a source of payment shock and foreclosure risk.

FHA is accepting feedback through September 18, 2026. NAR will continue working with the agency as it finalizes the guidance.

The National Association of REALTORS commented on the Appraiser Qualifications Board's Second Exposure Draft of Proposed Changes to the Real Property Qualification Criteria. The letter focused on expanding pathways into the appraisal profession, maintaining competency, and ensuring public trust.

While NAR supports broader, more accessible routes, to the appraisal profession, concerns were raised about the lack of experience requirements and quality control for demonstration reports. NAR encouraged recognition of parallel experience in real estate analysis, brokerage, and related fields, as recognition of overlapping real estate coursework and experience would reduce repetition.

NAR also called for clear standards to evaluate competency and experience across diverse pathways, emphasizing the importance of transparency in verification processes.

NAR also commented on changes to the fair housing education component, supporting retaining the education but opposing making it optional for continued education. The letter warned that reducing course hours should not diminish practical knowledge on fair housing laws, and stressed fair housing as a core component of appraiser competency.

NAR expressed appreciation for ongoing stakeholder engagement and clear communication but recommended detailed explanations of changes and implementation guidance to ensure consistency across jurisdictions.

Read the letter

https://www.narfocus.com/file/7707.pdf