Guide · Lenders
Lenders, Banks & Credit Unions
Small-dollar mortgages, appraisal rules, URLA changes, and a community-bank title.
23 relevant sections 10 action items 26 tracked deadlines
The one thing to know
Mortgage lenders get an FHA small-dollar pilot, new appraiser and reconsideration-of-value rules, and URLA changes on a six-month clock; community banks get brokered-deposit, exam-cycle, and de novo relief that is already law.
The Act reaches lenders from two directions. On the mortgage side, Section 105 lets FHA stand up a pilot within a year for mortgages of $100,000 or less (lender payments, adjusted FHA terms, borrower grants), Sections 401–402 send CFPB to report on loan-originator compensation and the QM points-and-fees thresholds for small loans (due about April 7, 2027), Section 403 lets state-licensed as well as certified appraisers do FHA appraisals via a mortgagee letter due about March 8, 2027, and Section 704 requires USDA, VA, FHA and FHFA to make lenders keep reconsideration-of-value procedures. Sections 601 and 603 require FHFA to add a military-service question and VA-eligibility prompt to the URLA within six months and add a VA cost comparison to FHA’s informed-consumer-choice notice.
On the banking side, Title IX (Sections 901–909) is self-executing in large part: custodial deposits at well-run banks under $10 billion are not brokered up to 20% of liabilities, reciprocal-deposit exclusions are tiered, the 18-month exam cycle threshold rises from $3 billion to $6 billion, well-rated federal credit unions may meet six times a year, and regulators must streamline de novo applications and run a capital phase-in pilot. Section 203 raises the public-welfare-investment cap to 20%. Section 1001, the institutional-investor purchase ban, matters for servicers and loan-sale bidders — HUD is already requiring Title X attestations in loan sales.
What changes for you
All sections tagged for youThe sections below are the ones this guide leans on, in the order they matter most. Each links to the full plain-English breakdown and the enrolled text.
- Sec. 105pilotFHA Small-Dollar MortgagesAuthorizes (but does not require) HUD, through the FHA Commissioner, to launch a pilot within one year to expand access to mortgages of $100,000 or less on one- to four-unit principal residences. Tools can include direct payments to lenders, adjusted FHA terms and costs, borrower grants for down payment, closing, appraisal, and title insurance, outreach, and lender technical assistance. FHA must report annually to Congress, including a 10-year look-back and an analysis of risk to the MMI Fund.Read the breakdown
- Sec. 203reformCommunity Investment and Prosperity ActRaises the outer ceiling on public welfare investments — the authority national banks and state member banks use for LIHTC and other community development equity — from 15 percent to 20 percent of capital and surplus. It does not change the default aggregate cap of 5 percent plus 5 percent, which remains exceedable only on a Comptroller (or Federal Reserve Board) order that the higher amount poses no significant risk to the deposit insurance fund and the bank is adequately capitalized. The OCC and Federal Reserve must each report to Congress every two years on the number and dollar volume of these investments by purpose, type, bank size, and state.Read the breakdown
- Sec. 401reportCreating Incentives for Small-Dollar Loan OriginatorsOrders the CFPB Director to report to Congress within 270 days on how loan originators are paid across the mortgage market — salary, fixed-percentage commission, other commission structures, volume-based pay, and capped or floored commissions — and how those practices affect the availability of small-dollar mortgages ($100,000 or less) that are FHA-insured, VA- or USDA-backed, or GSE-eligible. §401(c) directs that the report give due consideration to CDFI compensation practices — though as enrolled it assigns that duty to "the Secretary," a term the section never defines (the report itself is the CFPB Director’s under §401(b)). The Senate’s grant of rulemaking authority was dropped.Read the breakdown
- Sec. 402studySmall-Dollar Mortgage Points and FeesRequires the CFPB, in consultation with HUD and FHFA, to evaluate within 270 days how "the thresholds under section 1026.43" of Regulation Z — the ability-to-repay and qualified mortgage rule — affect originations of mortgages under $100,000. The section heading points at points and fees, but the operative text is not limited to them. It is an evaluation, not a rule; the Senate’s rulemaking authority was removed.Read the breakdown
- Sec. 403reformAppraisal Industry Improvement ActModernizes appraiser rules on two fronts. For FHA: roster appraisers must be state licensed or certified (federal employee appraisers need only one state), meet the USPAP competency rule, and complete an FHA-specific education course, implemented through a HUD mortgagee letter within 240 days that takes effect within 180 days after issuance. For the broader system: FIRREA amendments add state-credentialed trainee appraisers to the national registry, let certified appraisers use trainees while remaining liable, let the Appraisal Subcommittee adjust AMC registry fees and make workforce and training grants to state agencies and post-secondary schools, and add VA, RHS, and HUD to the Appraisal Subcommittee.Read the breakdown
- Sec. 601reformMilitary Service QuestionRequires FHFA to make Fannie Mae and Freddie Mac add a short prompt to the Uniform Residential Loan Application, right below the military-service question and above the signature line: "If yes, you may qualify for a VA Home Loan. Consult your lender regarding eligibility." GAO must then study whether fewer than 80 percent of lenders using the URLA actually include it.Read the breakdown
- Sec. 602reformHousing Unhoused Disabled Veterans ActFixes a long-standing barrier for disabled veterans: VA disability compensation and pension (38 U.S.C. chapters 11 and 15) no longer counts when determining income eligibility for HUD-VASH, or when a HUD-VASH household is evaluated for other housing assistance. The benefits still count as income when a PHA calculates adjusted income and the family’s rent share. A parallel exclusion applies to veterans renting HUD-assisted units built on VA property after enactment.Read the breakdown
- Sec. 603reformVeterans Affairs Loan Informed Disclosure (VALID) ActMakes sure borrowers who might qualify for a VA loan learn about it. The FHA "informed consumer choice" disclosure must now compare the cost of FHA insurance against a VA-guaranteed loan at prevailing rates (lenders need not determine VA eligibility), and FHFA must require the Enterprises to put a Yes/No/Prefer Not To Answer military-service question above the URLA signature line, with a rule due in 6 months.Read the breakdown
- Sec. 704reformAppraisal Modernization ActTwo appraisal-fairness steps. First, USDA, VA, the FHA Commissioner and FHFA must each require creditors on federally backed mortgage loans to keep a review-and-resolution procedure for consumer-initiated reconsideration of value or a second appraisal on principal-dwelling loans. Second, GAO must report within 240 days on the feasibility of a public, appraisal-level database consolidating data held by FHFA (for the Enterprises), HUD/FHA, USDA and VA — followed by mandatory hearings in both housing committees.Read the breakdown
- Sec. 901reformCommunity Bank Deposit AccessCarves certain custodial deposits out of the FDIC’s brokered-deposit rules for smaller, healthy banks. Custodial deposits placed by a bank, bank-controlled trust entity, state trust company, or ERISA plan administrator or adviser acting as fiduciary are not "brokered" at an eligible institution — one under $10 billion in assets, CAMELS 1–3 and well capitalized (or holding a waiver) — up to 20 percent of the bank’s total liabilities. A bank that accepts such deposits while not well capitalized faces an interest-rate cap.Read the breakdown
- Sec. 902reformKeeping Deposits LocalExpands and tiers the reciprocal-deposit exclusion from brokered-deposit treatment. Instead of a flat cap, an agent institution may exclude 50 percent of its first $1 billion of liabilities, 40 percent of liabilities between $1 billion and $10 billion, and 30 percent of liabilities between $10 billion and $96,333,333,333. The "agent institution" test moves to a CAMELS 1–3 rating, and the FDIC must study reciprocal deposits within 6 months.Read the breakdown
- Sec. 903reformTailored Regulatory Updates for Supervisory TestingA one-line change with real supervisory impact: the total-asset threshold that lets qualifying banks be examined on an 18-month (rather than 12-month) on-site cycle doubles from $3 billion to $6 billion.Read the breakdown
- Sec. 904reformCredit Union Board ModernizationRelaxes the Federal Credit Union Act’s monthly board-meeting mandate for well-run credit unions. De novo federal credit unions still meet monthly for their first five years, and credit unions with composite or management ratings of 3, 4 or 5 keep meeting monthly, but those rated 1 or 2 on both measures may meet six times a year with at least one meeting per quarter.Read the breakdown
- Sec. 905oversightSystemic Risk Authority TransparencyAn accountability measure for bank failures. Whenever the FDIC’s "systemic risk exception" to least-cost resolution is invoked, GAO must report to Congress within 60 days and again 180 days later on the basis for the determination, its effect on bank and depositor incentives, executive and board mismanagement, compensation practices, supervisory shortcomings, regulator and Treasury actions, and other contributors. The failed bank’s primary federal regulator must also file its own reports — including three years of exam reports and material supervisory determinations — and publish them "to the fullest extent possible."Read the breakdown
- Sec. 906reformAdvancing the Mentor-Protege Program for Small Financial InstitutionsCodifies a Treasury "Financial Agent Mentor-Protégé Program" in FIRREA §308. Designated financial agents and large financial institutions ($50 billion or more in assets) may mentor small financial institutions — those at or below $2 billion, minority depository institutions, or rural depositories under $10 billion — so they can qualify as government financial agents or build capacity to serve customers. Treasury must hold outreach events at least annually, set an exclusion process, and report participation to Congress.Read the breakdown
- Sec. 907reformAmerican Access to BankingDirects the federal financial regulators (Fed, OCC, FDIC and NCUA) to make it easier to charter new banks and credit unions. They must review and streamline de novo application forms, pull information from other government sources to minimize applicant requests, review capital-raising rules with the SEC, assign a caseworker to any de novo applicant that asks, connect applicants with recently approved institutions willing to mentor, and develop state and stakeholder engagement plans with public comment.Read the breakdown
- Sec. 908pilotPromoting New Bank FormationA pilot to encourage new community banks. The federal banking agencies may allow a two-year phase-in of capital requirements for "qualifying community banks" — institutions with under $10 billion in combined assets that become insured between January 1, 2026 and December 31, 2028 — and those banks may ask to deviate from their approved business plans during their first two years, with the agency required to act within 180 days. The agencies must study the pilot (report by December 31, 2031) and separately study why so few de novo banks have formed (report in 1 year).Read the breakdown
- Sec. 909studyRural Depositories Revitalization StudyTwo parallel studies of rural financial institutions. The Fed, OCC and FDIC jointly — and NCUA separately for credit unions — must identify ways to improve the growth, capital adequacy and profitability of depository institutions that primarily serve rural areas, and identify federal statutes and regulations that limit those methods or the formation of new rural institutions. Reports to Congress are due within 1 year.Read the breakdown
- Sec. 1001prohibitionHomes Are for People, Not CorporationsThe Act’s most debated provision. Starting 180 days after enactment (January 7, 2027), a "large institutional investor" — a for-profit fund, corporation, partnership, LLC or similar entity in the business of investing in single-family homes that, alone or in concert, has investment control of at least 350 single-family homes — may not purchase or contract to purchase any single-family home (a structure with 2 or fewer units; manufactured homes excluded). Eleven categories of "excepted purchases," including build-to-rent and homes built or renovated for sale, are carved out. Treasury (or DOJ at Treasury’s request) can seek civil penalties of up to $1,000,000 per violation or three times the purchase price, whichever is greater, and HUD must run a renter outreach resource. The prohibition and enforcement provisions are repealed 15 years after they take effect.Read the breakdown
- Sec. 101reformReforms to Housing Counseling and Financial Literacy ProgramsRewrites the rules for HUD’s housing counseling grants. Grantees must be geographically diverse and include organizations serving urban or rural areas, HUD must conduct performance reviews of every funded organization, and HUD may compare each pre-purchase counselor’s borrower default rates against comparable markets — with continuing education, retesting, and eventual suspension of certification for counselors who repeatedly fall short. It also guarantees delinquent FHA, Section 184/184A, VA, and USDA borrowers an opportunity for counseling.Read the breakdown
- Sec. 702reportFHA Reporting Requirements on Safety and SoundnessAdds a standing transparency duty for FHA. HUD must send Congress monthly reports on the Mutual Mortgage Insurance Fund’s capital ratio required by National Housing Act §205(f)(2) and must notify Congress "as soon as practicable" if the Fund drops below that ratio.Read the breakdown
- Sec. 303reformProperty Improvement and Manufactured Housing Loan Modernization ActRaises FHA Title I loan limits substantially: $75,000 for single-family (including manufactured home) improvement loans; $150,000 per structure and $37,500 per unit for multifamily improvements; $106,405 (single-section) and $195,322 (multi-section) for manufactured homes; $149,782 and $238,699 for home-plus-lot; and $43,377 for a lot alone. It makes accessory dwelling unit construction an eligible Title I purpose, lets terms run up to 30 years, lets HUD set and index limits by notice, and orders a HUD study of offsite (manufactured and modular) construction cost-effectiveness.Read the breakdown
- Sec. 1101prohibitionCentral Bank Digital CurrencyUnrelated to housing but part of the final deal. New Federal Reserve Act §16A bars the Federal Reserve Board and any Federal Reserve Bank from issuing or creating a central bank digital currency — a dollar-denominated U.S. currency that is a direct liability of the Federal Reserve System and widely available to the public — or any substantially similar digital asset, directly or through banks or other intermediaries. The prohibition sunsets December 31, 2030, and the section states that nothing in it authorizes a CBDC without an Act of Congress.Read the breakdown
Source: Enrolled bill text, H.R. 6644 (govinfo) (opens in a new tab) · Section numbers as enacted · reviewed Aug 29, 2026
Your action checklist
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Now
Already law — no guidance needed to start.Rest of 2026
Deadlines and data calls landing before year-end.Why: The purchase ban starts January 7, 2027; loss mitigation after foreclosure or deed-in-lieu is an excepted purchase, and HUD’s August 10, 2026 HNVLS notice already requires attestations.
2027
Decisions that wait on agency notices or appropriations.Why: Section 704 directs each agency and FHFA to require creditors to maintain consumer-initiated ROV and second-appraisal procedures; GAO also owes a report on a public appraisal database within 240 days.
Why: The pilot can pay lenders directly, adjust FHA terms, and fund borrower grants for down payment, closing, appraisal and title insurance — subject to appropriations.
Why: Section 403 expands FHA appraiser capacity and adds HUD, VA and USDA to the Appraisal Subcommittee.
Watch
Nothing to do yet — keep an eye on rulemaking and NOFOs.Why: Section 101 adds the delinquency-counseling requirement (FHA counseling costs paid from the MMI Fund when capital tests are met); the rule has no fixed deadline.
Deadlines that matter to you
| Deadline | Section | Agency | Action | Status |
|---|---|---|---|---|
| Oct 9, 2026in 36 days | Sec. 502 | USDA-RHS | Report to House Financial Services and Senate Banking on how quickly USDA decides Section 502 and 504 loan and grant applications, with justifications for eligibility determinations that take longer than 90 days and recommendations to shorten timelines (§502(s)).Not later than 90 days after the date of enactment of this Act, and annually thereafter until the date described in subparagraph (B)No public record of the first report as of late August 2026. The series is self-extinguishing: §502(s)(2)(B) ends it once USDA has, over the preceding 5-year period, made every eligibility determination within 90 days. | Not started |
| Jan 7, 2027in 126 days | Sec. 1001 | HUD | The Title X restriction on large institutional investors purchasing single-family homes takes effect, along with the related requirements in §1001(b) and (d). Enforcement is by Treasury (or the Attorney General at Treasury’s request); HUD runs the renter outreach resource and receives investor notifications. The restriction is repealed 15 years after the effective date (Jan 7, 2042).Shall take effect on the date that is 180 days after the date of enactment of this ActNo implementing guidance from HUD, Treasury, or DOJ yet. HUD’s Aug 10, 2026 loan-sale notice is the first operational reference: bidders must attest that purchases will not result in acquisitions prohibited by Title X. | Not started |
| Jan 7, 2027in 126 days | Sec. 1001 | Other | Each large institutional investor notifies HUD whether it meets the statutory definition and reports how many single-family homes it controls and where (city and state), unless it owns 10 or fewer homes in a city. First notice at 180 days, then every Dec 31.Not later than 180 days after the date of the enactment of this Act, and not later than December 31st of each year thereafterObligation sits with investors; HUD has not published a form or submission channel yet. | Not started |
| Jan 11, 2027in 130 days | Sec. 601 | FHFA | By regulation or order, require Fannie Mae and Freddie Mac to add a disclosure under the military service question on the Uniform Residential Loan Application: "If yes, you may qualify for a VA Home Loan. Consult your lender regarding eligibility."Not later than 6 months after the date of enactment of this sectionNo FHFA rule or order yet. A July 26, 2026 letter from Sens. Warren and Schumer urged the FHFA Director to prioritize the ROAD directives. | Not started |
| Jan 11, 2027in 130 days | Sec. 603 | FHFA | Require the Enterprises to place a military service question ("Yes," "No," "Prefer Not To Answer") above the signature line of the URLA, and issue a rule to carry out the amendment (VALID Act).Not later than 6 months after the date of enactment of this ActNo FHFA rulemaking yet. The companion FHA piece, adding a VA-loan comparison to the Informed Consumer Choice Disclosure, has no statutory clock and is "under evaluation" per FHA INFO 2026-18. | Not started |
| Jan 11, 2027in 130 days | Sec. 902 | Banking regulators | FDIC reports to House Financial Services and Senate Banking on its study of reciprocal deposits, including benefits and potential risks (Keeping Deposits Local).Not later than 6 months after the date of enactment of this ActThe 6-month report to Congress is still pending, but §902 rulemaking has begun: on August 27, 2026 the FDIC Board approved an interim final rule implementing the section’s reciprocal-deposit amendments — a tiered, liability-based exclusion from brokered-deposit treatment of up to $30 billion and a broader "agent institution" definition — with comments due 30 days after Federal Register publication. | In progress |
| Mar 8, 2027in 186 days | Sec. 403 | FHA | Issue a mortgagee letter or guidance implementing the new FHA appraiser eligibility rules (licensed as well as certified appraisers, trainee flexibility), spelling out requirements and a way for appraisers to show prior compliance. The guidance must take effect within 180 days of issuance.Not later than the 240 days after the date of enactment of this ActFHA INFO 2026-18 (Aug 12, 2026) says ROAD provisions are "under evaluation" and were not included in the latest Handbook 4000.1 update. | In progress |
| Mar 8, 2027in 186 days | Sec. 704 | GAO | Publish a report assessing the feasibility, costs, benefits, and risks of a public, searchable appraisal-level database consolidating data held by FHFA, the Enterprises, HUD/FHA, USDA, and VA (Appraisal Modernization Act).Not later than 240 days after the date of enactment of this ActNo GAO product citing the Act yet. | Not started |
| Apr 7, 2027in 216 days | Sec. 401 | CFPB | Report to Senate Banking and House Financial Services on loan originator compensation practices across the mortgage market, including how originators are paid on small-dollar loans.Not later than 270 days after the date of enactment of this ActNo CFPB action citing the Act as of late August 2026. | Not started |
| Apr 7, 2027in 216 days | Sec. 402 | CFPB | In consultation with HUD and FHFA, evaluate how the thresholds under Regulation Z §1026.43 affect originations of small-dollar mortgages (under $100,000). The section heading points at points and fees; the operative text is not limited to them.Not later than 270 days after the date of enactment of this ActNot started publicly. | Not started |
| Jul 11, 2027in 311 days | Sec. 105 | FHA | The FHA Commissioner may establish a small-dollar mortgage pilot (e.g., direct payments to lenders); annual reports begin one year after establishment; the pilot sunsets four years after it starts, and the authority to newly establish one expires three years after enactment.Not later than 1 year after the date of the enactment of this sectionDiscretionary ("may establish"), and no funds are authorized — so there is no mandatory clock here, only a window. FHA lists ROAD provisions as "under evaluation" (FHA INFO 2026-18), which does not tell us whether this pilot is among them. | Unknown |
| Jul 11, 2027in 311 days | Sec. 301 | HUD | States submit an initial certification that their laws treat manufactured homes without a permanent chassis in parity with chassis-built homes (financing, title, insurance, manufacture, sale, taxes, transportation, installation); HUD publishes and maintains a Federal Register and website list of states that are current. States with biennial legislatures get two years.Not later than 1 year after the date of enactment of the 21st Century ROAD to Housing ActThis is the date that carries a real consequence: under new NMHCSSA §604(i)(5)(B), a State that fails to certify must itself prohibit the manufacture, installation, or sale of covered chassis-less manufactured homes within the State. No HUD certification form or guidance to states yet, and HUD has not said how it will reconcile its June 12, 2026 proposed rule (which lifted the chassis requirement only for upper floors) with §301. | Not started |
| Jul 11, 2027in 311 days | Sec. 301 | HUD | Adopt minimum energy efficiency standards for manufactured homes through the consensus committee process, then update them at least every three years.Not later than 1 year after the date of enactment of this ActNot issued. | Not started |
| Jul 11, 2027in 311 days | Sec. 302 | HUD | Publish a report on barriers to modular construction in FHA construction financing programs, then start a rulemaking on an alternative draw schedule within 120 days of the report (Modular Housing Production Act).Not later than 1 year after the date of enactment of this ActFHA lists ROAD provisions as "under evaluation" (FHA INFO 2026-18); no report yet. | In progress |
| Jul 11, 2027in 311 days | Sec. 303 | HUD | Develop or choose one or more methods for indexing Title I manufactured home loan limits (the pre-Act method applies in the interim), and separately study and report to Congress on the cost effectiveness of offsite (manufactured and modular) construction.Not later than 1 year after the date of enactment of this ActUnder evaluation per FHA INFO 2026-18; nothing issued. | In progress |
| Jul 11, 2027in 311 days | Sec. 907 | Banking regulators | Each federal financial institutions regulatory agency reports to Congress and posts publicly on actions taken to review capital-raising restrictions for de novo institutions, and publishes information on how to request or serve as a de novo mentor.Not later than 1 year after the date of enactment of this Act, and annually for 5 years thereafterNot issued. FDIC FIL-48-2026 (Aug 10, 2026) revised de novo application procedures but cites only the FDI Act, not the ROAD Act. A stakeholder engagement plan is due at the two-year mark. | Not started |
| Jul 11, 2027in 311 days | Sec. 908 | Banking regulators | Federal banking agencies jointly report to Congress on their study of why so few de novo banks formed over the past decade, how to promote new banks in underserved areas, and how de novo, rural, CDFI, and minority institutions can use the Community Bank Leverage Ratio (Promoting New Bank Formation).Not later than the end of the 1-year period beginning on the date of enactment of this ActNot issued. A separate joint study report is due Dec 31, 2031. | Not started |
| Jul 11, 2027in 311 days | Sec. 909 | Banking regulators | Federal banking agencies jointly report to Congress on rural depository institutions, and NCUA reports separately on rural credit unions, including de novo formation in rural areas.Not later than 1 year after the date of enactment of this ActNot issued. | Not started |
| Jan 11, 2028in 495 days | Sec. 601 | GAO | Study and report to Congress on whether fewer than 80 percent of lenders using the URLA have included the VA-loan disclosure required by new §1329.Not later than 18 months after the date of enactment of this ActPending; depends on FHFA acting first (Jan 11, 2027). | Not started |
| Jul 11, 2028in 677 days | Sec. 203 | Banking regulators | OCC and the Federal Reserve Board each report to Congress (every two years) on public welfare investments made by national banks and state member banks under the raised 20 percent cap.Not later than 2 years after the date of enactment of this section, and every 2 years thereafterRecurring biennial report; the cap increase itself is self-executing. | Not started |
| Jul 11, 2028in 677 days | Sec. 907 | Banking regulators | Each federal financial institutions regulatory agency submits its state and stakeholder engagement plan for de novo formation to Congress, then every five years.Not later than 2 years after the date of enactment of this Act, and every 5 years thereafterNot issued. | Not started |
| Jan 7, 2029in 857 days | Sec. 1001 | GAO | GAO and HUD (with Treasury, RHS, VA Loan Guaranty, SEC and others) each report on the impact of large institutional investor ownership on availability and affordability and on the effectiveness of the purchase restriction; repeated at the 10-year mark.Not later than 2 years after the date on which the prohibition under subsection (b)(1) takes effect, and again not later than 10 years after that dateComputed from the Jan 7, 2027 effective date. | Not started |
| Jul 11, 2029in 1042 days | Sec. 211 | FHA | The FHA Commissioner reports to Congress on the study of multifamily loan limits and their effect on production (Housing Affordability Act).Not later than 3 years after the date of enactment of this ActThe loan-limit changes themselves are under evaluation at FHA (FHA INFO 2026-18). | Not started |
| Dec 31, 2030in 1580 days | Sec. 1101 | Federal Reserve | The prohibition on the Federal Reserve issuing a central bank digital currency (directly or through an intermediary) stays in force until its statutory sunset.This provisions of this section shall cease to be effective on December 31, 2030Self-executing prohibition with a fixed sunset; no agency action required. | Not started |
| No statutory deadline | Sec. 301 | HUD | Revise the Manufactured Home Construction and Safety Standards, through the consensus committee process, to cover manufactured homes built without a permanent chassis (new NMHCSSA §604(a)(7)).The Act sets no date for this rulemaking, but the chassis-less definition is already in force — so the standards a chassis-less home must meet are, for now, unwritten. Nothing has been proposed. | Not started |
| Monthly reports (no start date specified) | Sec. 702 | FHA | Send Congress monthly reports on the MMI Fund capital ratio and notify Congress as soon as practicable if the Fund falls below the required ratio.Reports go to Congress; whether FHA has begun is not visible in the public record. | Unknown |
Source: Enrolled bill text, H.R. 6644 (govinfo) (opens in a new tab) · Status as of Aug 29, 2026; day counts relative to Sep 3, 2026 (Eastern)
Full implementation trackerWatch-outs
Sections 401–402 are studies, not rules — the Senate’s CFPB rulemaking authority was dropped in the final text.
The Act contains no GSE reform, no credit-scoring provisions, and no change to Davis-Bacon; Section 702 only adds monthly MMI Fund capital-ratio reports to Congress.
Section 908 has an internal inconsistency (180-day review versus a 90-day deemed-approval clause) that has not been corrected as of August 2026.
The FHA small-dollar pilot is discretionary ("may") and subject to appropriations; nothing obliges FHA to launch it.
Section 1101 (no Fed central bank digital currency, sunset December 31, 2030) is in the same law but has no direct lending effect.
Resources for you
Full library- bill textGovInfo (GPO) · Jun 25, 2026H.R. 6644 — Enrolled bill text (21st Century ROAD to Housing Act) (opens in a new tab)
The enrolled text as sent to the President — the version this hub quotes. Use it to check any section heading, deadline, or dollar figure.
- explainerBipartisan Policy Center · Mar 10, 2026BPC — What’s in the 21st Century ROAD to Housing Act? (opens in a new tab)
BPC’s explainer of the merged Senate text (March 2026). Section numbers here pre-date the House amendment — check against the enrolled text.
- trackerBipartisan Policy Center · Jul 20, 2026BPC — 21st Century ROAD to Housing Act Implementation Tracker (opens in a new tab)
Deadline-by-deadline tracker of required agency actions (e.g., investor restriction effective Jan 7, 2027; program sunsets from 2031). Updated periodically.
- explainerSenate Banking Committee · Mar 2, 2026Fact sheet — large institutional investors (Title X) (opens in a new tab)
One-pager on the 350-home institutional-investor restriction as proposed in March 2026 (before the House removed the seven-year rule).
- otherSenate Banking Committee (Minority) · Jul 26, 2026Warren/Schumer letter to FHFA Director Pulte urging implementation of ROAD directives (opens in a new tab)
Post-enactment oversight letter pressing FHFA on the Act’s directives (including the URLA military-service question and VA disclosure).
- otherFederal Register · Jan 23, 2026Executive Order 14376 — Stopping Wall Street From Competing With Main Street Homebuyers (opens in a new tab)
The January 2026 executive order that Title X of the Act codifies and extends. Read alongside Sec. 1001.
- agency guidanceHUD / Federal Register · Aug 10, 2026HUD Non-Vacant Loan Sale (HNVLS 2026-1) — bidder attestation referencing Title X (opens in a new tab)
HUD’s first operational reference to the institutional-investor restriction: loan-sale bidders must attest their acquisitions won’t violate Title X.
- agency guidanceHUD / FHA · Aug 12, 2026FHA INFO notices (FHA INFO 2026-18: ROAD provisions “under evaluation”) (opens in a new tab)
FHA’s only written statement on the Act so far — Handbook 4000.1 update explicitly excludes ROAD provisions pending evaluation. Watch this page for small-dollar pilot and appraisal guidance.
- agency guidanceHUD / Federal Register · Jun 12, 2026HUD proposed rule — Revising the Definition of “Manufactured Home” to Lower Housing Costs (opens in a new tab)
Pre-enactment chassis rulemaking that Sec. 301 now overtakes; HUD has not yet said how it will reconcile the two.
- trackerNational Association of Affordable Housing Lenders · Jul 12, 2026NAAHL — ROADmap: Implementation Guide and action matrix (opens in a new tab)
Maps 124 required federal actions (58 due in year one) with a downloadable matrix — the most granular implementation inventory available.
- trackerNational Association of Affordable Housing Lenders · Jul 12, 2026NAAHL ROADmap — full implementation guide (PDF) (opens in a new tab)
The PDF version of the ROADmap.
- explainerAmerican Enterprise Institute · Apr 10, 2026AEI Housing Center — Senate investor ban would cut supply, hurt low-income families (opens in a new tab)
Data-driven critique of the Senate’s seven-year rule; several of its recommended fixes made it into the final Title X.
14 more tagged for lenders, banks & credit unions in the full library.
FAQ for you
All questions & glossaryWhere this guide comes from
- Enrolled text of H.R. 6644 (govinfo) (opens in a new tab)
- Consumer Finance Monitor: small-dollar mortgage provisions (June 26, 2026) (opens in a new tab)
- HUD HNVLS 2026-1 (Title X attestation, Aug 10, 2026) (opens in a new tab)
- BPC explainer (opens in a new tab)
Guide reviewed August 29, 2026. Not legal or compliance advice — confirm against the enacted text and agency guidance before acting.
Related explainers
The Act and the Housing Credit
This guide cites LIHTC repeatedly. The Act does not amend the Housing Credit — the 2025 tax law did. Which law changed what, kept apart.
Read the comparisonAppropriations Watch
Whether the programs in this guide have FY2027 money — the House bill, the Senate bill that does not exist, and the two pending continuing resolutions.
Check the moneyComment & Engage
Federal comment periods open now, how to write one an agency has to reckon with, and the dockets the Act guarantees are still coming.
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