The MBA Is Talking About Loss Mitigation This Week. Here’s What We’re Watching.
On June 10th, the Mortgage Bankers Association is hosting a webinar on new and evolving loss mitigation options, focused specifically on identifying early-stage risk before delinquencies escalate. The session is aimed at servicing and default leadership, and the timing reflects something the industry is feeling broadly right now: the environment has shifted and the old playbook isn’t keeping up.
We submitted a question ahead of the session about FHA’s 90-day review requirement. It’s a topic that’s been sitting at the center of a lot of conversations we’re having with servicers, and one that deserves more attention than it typically gets.
What the Requirement Demands
FHA’s April 2026 FAQ removed any remaining ambiguity around a rule that has been in Handbook 4000.1 for years. Before four monthly installments are due and unpaid, servicers must complete a loss mitigation evaluation, send a written borrower-specific notice with the eligibility determination, retain documentation that the review was completed, and document outreach efforts made before the deadline.
The requirement isn’t new. What’s new is the question of how servicers demonstrate borrower-specific compliance when the process no longer requires borrower-specific documentation to reach a determination. With FHA delinquencies rising, that operational gap is becoming harder to ignore.
Why It Matters Right Now
The MBA’s session is focused on proactive engagement and early intervention, which is exactly where the 90-day requirement lives. Getting in front of a delinquent borrower before the four-month mark isn’t just good servicing practice. It’s what FHA policy demands, and what the data supports.
When borrowers receive a clear explanation of every option available to them early in the delinquency cycle, they engage. That’s what we’re seeing in practice, and it’s the operational case behind the compliance one.
We’ll share our perspective on what the session covered after June 10th.
In the meantime, our white paper on the 90-day review requirement covers what FHA expects, where the common gaps are, and how to close them. Available to download at https://waterfallcalc.com/loss-mitigation/.
