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On October 2, 2025, three federal agencies published major updates in the Federal Register affecting small business lending, reverse mortgage programs, and the housing finance system. The actions included a final rule from the Consumer Financial Protection Bureau (“CFPB”), a Request for Information from the Department of Housing and Urban Development (“HUD”), and two rulemaking updates from the Federal Housing Finance Agency (“FHFA”). Together, these developments reflected a mix of compliance extensions, program reassessment, and agenda resets across the lending and housing landscape.
1) CFPB: published a final rule under Regulation B that finalized its June 18, 2025, interim final rule extending compliance dates for the 2023 small-business lending rule (originally from Section 1071 of the Dodd-Frank Act and adjusted in 2024), and made conforming date-related edits. The action delayed initial data-collection start dates (New Compliance Dates: Tier 1, July 1, 2026; Tier 2, January 1, 2027; Tier 3, October 1, 2027) while leaving the underlying reporting framework intact; the rule becomes effective 60 days after publication.
What it means: Lenders receive more time to prepare for data collection obligations but the underlying reporting requirements remain firmly in place.
For more information, please Click Here.
2) HUD: through Federal Housing Administration (FHA) and Ginnie Mae, issued a Request for Information on the future of the Home Equity Conversion Mortgage (HECM) program and HECM reverse-mortgage program and (HMBS) securitization, seeking market feedback on operational improvements, liquidity, and innovation to help seniors access home equity. Comments are due December 1, 2025.
What it means: Market participants, investors, and senior advocates are given a chance to influence potential program changes that could impact liquidity, servicing, and the availability of reverse mortgages.
For more information, please Click Here.
3) FHFA: issued two actions. First, a proposed rule established draft housing goals for Fannie Mae and Freddie Mac for 2026–2028, consolidating certain benchmarks, adjusting penalty calculations, and simplifying compliance determinations. Stakeholders are given 30 days after date of publishing to submit comments on the proposal. This was intended to guide the Enterprises’ affordable housing mandates over the next three years. Second, FHFA formally withdrew earlier proposals related to enterprise liquidity requirements, Federal Home Loan Bank board governance, and unsecured credit limits. The aim is to reset the regulatory agenda in these areas and revisit them through future rulemakings if needed.
What it means: The proposed goals may shift how Fannie Mae and Freddie Mac meet affordable housing benchmarks. The withdrawals may provide short-term regulatory clarity but leave open the possibility of new initiatives in the future.
For more information, Click Here (Enterprise Liquidity Requirements) and Here (Enterprise Housing Goals).
DISCLAIMER
This publication may constitute attorney advertising under the laws and rules of professional conduct of one or more states. The information provided in this publication is for general informational purposes only and does not constitute legal advice. The contents are not intended to be a substitute for professional legal advice, consultation, or representation. No attorney-client relationship is formed by reading or relying on this publication. Prior results do not guarantee a similar outcome. Readers should consult a qualified attorney for advice regarding their individual circumstances or any specific legal questions they may have.
If you have questions about this publication, please contact Adam Friedman, Ralph Vartolo or Michael DeRosa,
Friedman Vartolo LLP, 1325 Franklin Avenue, Suite 160, Garden City, NY 11530, Phone: (212) 471-5100 | Fax: (212) 471-5150.




