Policies


Selected policies and regulations

Federal Housing Finance Agency


Advisory Bulletin 2024-07: FHLBank Fair Lending and Fair Housing Compliance

James oversaw the establishment of regulatory guidance on compliance by the Federal Home Loan Banks (FHLBank) with fair lending and fair hosuing laws. This guidance addressed potential fair lending and fair housing issues in FHLBank policies and procedures, mortgage purchase programs, advances, and affordable housing and community development grant programs.

This guidance was rescinded by FHFA Director Bill Pulte in 2025.

Advisory Bulletin 2024-06: Regulated Entity Unfair or Deceptive Acts or Practices Compliance

James oversaw the establishment of regulatory guidance on compliance by Fannie Mae, Freddie Mac, and the Federal Home Loan Banks with the prohibition on unfair or deceptive acts or practices in violation of Section 5 of the Federal Trade Commission Act. This guidance addressed unfair and deceptive practices that impacted lenders, homebuyers, and renters.

Press: JD Supra, Vital Law

This guidance was rescinded by FHFA Director Bill Pulte in 2025.

Final Rule on Fair Lending, Fair Housing, and Equitable Housing Finance Plans

James oversaw the proposed and final rules that codified in regulation the FHFA’s Equitable Housing Finance Plan program and that established greater compliance requirements for fairness in Fannie Mae, Freddie Mac, and Federal Home Loan Bank programs.

Press: ABA Banking Journal, Vital Law, Housing Wire, Inside Mortgage Finance, The Mortgage Point

Parts of this rule were suspended by FHFA Director Bill Pulte in 2025.

Advisory Bulletin 2023-05: Enterprise Fair Lending and Fair Housing Rating System

James oversaw the establishment of a supervisory rating system for FHFA to rate fair lending and fair housing compliance management by Fannie Mae and Freddie Mac. The system is the first federal fair lending-focused financial regulator rating system.

Press: Inside Mortgage Finance

This guidance was rescinded by FHFA Director Bill Pulte in 2025.

Fair Lending Oversight Data System

James established the privacy and governance safeguards for a unified supervisory fair lending data oversight system at FHFA, compliant with the Privacy Act of 1974.

Directive for Mortgage Servicers to Maintain Fair Lending Data Elements

James oversaw the implementation of the FHFA policy to ensure that a borrower’s preferred language information collected on the Uniform Residential Loan Application (URLA) transfers through the loan lifecycle to mortgage servicers. The policy also ensures that basic fair lending data elements also transfer through servicing and requires servicers to maintain these data to ensure compliance with fair lending laws in their programs.

Press: Consumer Finance Monitor, Housing Wire, ABA Banking Journal

Federal Fair Lending Officials’ Comment Letter to Appraisal Foundation

James worked with the other fair lending senior officials at federal financial and housing regulators to take the rare step of commenting publicly on the revisions to the Uniform Standards of Appraisal Practice concerning issues of consistency with federal antidiscrimination law.

Press: Consumer Finance Monitor

Action Plan to Advance Property Appraisal and Valuation Equity

James served as FHFA’s representative on the PAVE taskforce and led FHFA’s efforts to address appraisal bias including changes to Fannie and Freddie appraisal policies to incorporate improvements to reconsideration of value, updates to policies to improve time adjustments and other barriers causing disparities, refer potential violations of law to HUD and to state appraisal regulators, and to release public appraisal data.

Press: New York Times

Equitable Housing Finance Plan Program

James created the FHFA Equitable Housing Finance Plan program under which Fannie Mae and Freddie Mac identified barriers to sustainable housing opportunities, set goals and action plans, and took meaningful actions to address the barriers identified. Under the 2022 - 2024 plans, thousands of homebuyers and renters received free education, credit report for on-time rental payments, downpayment assistance, and reduced closing costs.

Press: USA Today, Scotsman Guide, Affordable Housing Finance, Harvard Joint Center for Housing Studies, Inman

The Equitable Housing Finance Plan program was suspended by FHFA Director Bill Pulte in 2025.

Advisory Bulletin 2021-04: Enterprise Fair Lending and Fair Housing Compliance

James oversaw the establishment of regulatory guidance on compliance by Fannie Mae and Freddie Mac with fair lending and fair hosuing laws. This guidance addressed potential fair lending and fair housing issues in Fannie and Freddie policies and procedures, mortgage purchase programs, automated underwriting systems, multifamily lending, and management of real-estate owned property.

This guidance was rescinded by FHFA Director Bill Pulte in 2025.

FHFA/HUD Memorandum of Understanding on Fair Housing and Fair Lending Coordination

James drafted and negotiated the first memorandum of understanding between FHFA and HUD regarding fair lending and fair housing coordination. This MOU led to greater coordination of fair lending efforts in the federal government with respect to the mortgage market and housing programs.

Press: Housing Wire, Vital Law, Inside Mortgage Finance, National Mortgage Professional

Consumer Financial Protection Bureau


Uniform Residential Loan Application and Language Access Data Safe Harbor

James led the effort to review the new Uniform Residential Loan Application to ensure it met safe harbor status under Regulation B, and drafted the safe harbor document. The safe harbor also permitted creditors to collect language access data to better serve consumers with limited English proficiency. Regulation B was also amended to facilitate an orderly transition to the new HMDA reporting requirements and the new URLA. An earlier version of the safe harbor was also issued.

Press: Consumer Finance Monitor, National Mortgage News, Inside Mortgage Finance.

Application Process for Designation of Rural Area under Federal Consumer Financial Law

James supported the effort to implement the HELP Rural Communities Act process for creditors to apply for a rural area designation which allowed certain regulatory relief and exemptions from consumer financial regulations.

Home Mortgage Disclosure (Regulation C) Final Rule

James contributed significantly to implementing the Dodd-Frank Act amendements to the Home Mortgage Disclosure Act including adding several new data elements related to loan characteristics, multifamily housing, and manufactured housing.

U.S. Department of Housing and Urban Development


Implementation of the Fair Housing Act’s Discriminatory Effects Standard Final Rule

James contributed to the rulemaking codifying the Fair Housing Act’s discriminatory effects standard in regulation. The rulemaking was acknowledged and the doctrine of disparate impact under the Fair Housing Act was upheld by the Supreme Court in Texas Department of Housing and Community Affairs v. Inclusive Communities Project.

Press: Washington Post

Affirmatively Furthering Fair Housing Proposed Rule

James contributed to the proposed rule related to implementing Section 808(e)(5) of the Fair Housing Act, which requires HUD to administer the programs and activities relating to housing and urban development in a manner affirmatively to further the Fair Housing Act.

Press: New York Times, Washington Post