A trio of industry trade groups has suggestions for ways the White House can take action to meet a policy goal around making single-family homeownership more accessible to consumers without the legislation some other concepts require.

Ending a requirement to pay for three credit reports, reducing loan-level pricing adjustments and Federal Housing Administration insurance premiums all could help, finance and mortgage groups wrote in a letter sent to National Economic Council Director Kevin Hassett.

These moves "would help the administration make meaningful progress in increasing housing affordability," the Mortgage Bankers Association, Independent Community Bankers of America and America's Credit Unions said in the letter.

The broader current context for the letter

The Trump administration has been exploring several housing proposals with mentions of legislative involvement in many cases, including restrictions on institutional investor purchases of single-family homes, something the president said Wednesday he thinks Congress will pass.

Hassett has said that housing initiatives the administration has considered include a concept involving down payments on homes and 401(k) funds, which is similar to some past bipartisan proposals floated in Congress like the American Dream Act.

Potential cuts to the government-sponsored enterprises' LLPAs or the FHA's premiums are among housing ideas officials could consider, according to some analysts, who noted the impact on the finances of the agencies involved could be a challenge.

Hassett and agencies affected by these proposals had not responded to inquiries at the time of this writing, with the exception of the Department of Housing and Urban Development, which acknowledged receipt but did not immediately return any other response.

The rationale for lowering FHA premiums and LLPAs

The FHA has room in its finances to cut annual and/or life-of-loan mortgage insurance premiums because its current mortgage insurance fund's reserve ratio of almost 11.5% is far above the 2% statutory minimum, according to the coalition.

"Any MIP cut should be carefully coordinated with program adjustments to address rising delinquency rates or risk factors," the trade groups wrote, noting that LLPAs would need to be lowered if premiums were reduced to avoid shifting too much market share to the FHA.

The coalition specifically advocated for the enterprises to lower LLPAs for all sectors of the pricing grids for homebuyer loans and end them for refinances if the borrower has made timely payment for a year or more.

Varying views on the tri-merge

The coalition's position on the tri-merge contrasts that of groups such as the credit bureaus' Consumer Data Industry Association and the Community Home Lenders of America, which recently added arguments for its view that ending the requirement could add risks with costs.

"Variance across single consumer credit reports will dramatically impact risk and pricing," the CDIA said in a statement responding to the coalition's letter. "The MBA fails to acknowledge how tri-merge credit reports add stability."

Studies from different entities have drawn varying conclusions as to whether the differences between credit bureaus are significant when fewer than three reports get used and the Mortgage Bankers Associated has suggested further research.

The association also suggested in an earlier letter to a housing official that limiting the single report option it backs to only loans with scores of 700 or more indicating a higher likelihood of ability-to-repay could mitigate risks in not paying for reports from all the three major bureaus.

That housing official, Federal Housing Finance Agency Director Bill Pulte, oversees the government-sponsored enterprises that buy a large number of middle-class loans in the United States. Recent average scores for those loans have been in the 700-plus range.