Letter to the Hon. Benjamin Carson, Secretary of the Dept. of Housing and Urban Development - Brown demands HUD and independent financial regulators cease non-coronavirus related rulemaking during this public health emergency

Letter

Dear Secretary Carson --

I am writing to urge you to immediately cease all pending rulemaking processes at the Department of Housing and Urban Development (HUD) that are not a direct response to imminent health and safety concerns, or related to the effects of COVID-19. The Administration should suspend all rulemakings that are unrelated to or could impede our nation's response to the COVID-19 epidemic and instead focus and prioritize executive actions on activities related to advancing the public health and worker protections, increasing access to nutrition services, enhancing our nation's safety, and protecting the financial needs of individuals and families facing economic hardship as a result of the virus and response, or other imminent health and safety concerns. This cessation should include extension of any comment periods on rules not related to these critical health and safety factors closing after March 1, 2020.

The American people are scrambling to ensure they protect themselves, their families, and vulnerable individuals in society from this virus. Businesses, public institutions, and other organizations are devoting their resources to arrange alternative ways to carry out their activities as many of them take actions to protect their employees and the public. Under these circumstances, it will be difficult for the public to have the customary engagement with government agencies and provide meaningful recommendations and comments on proposed rulemakings other than those related to the crisis at hand.

In addition, HUD should focus its resources on providing reliable guidance to its mortgage market, fair housing, housing, and homelessness organization stakeholders and responding to the health and economic effects of this crisis rather than on processing other rulemakings. During this period, all rulemakings and comment periods closing after March 1, 2020 that are not related to the virus response or other imminent health, safety, or national security threats should be suspended or extended for at least 45 days.

The COVID-19 virus threatens both the health of the public and the economy. It presents immediate challenges to real households and every entity in the housing market, from frontline homelessness providers to homeowners. In light of this crisis, I urge you to implement an immediate moratorium on rulemakings not related to the virus response or other imminent health and safety concerns.

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