Preparing for Mortgage Document Changes Under the ROAD to Housing Act

The 21st Century ROAD to Housing Act became law on July 11, 2026. The legislation begins a broad federal housing-policy implementation effort, but it does not require immediate, industry-wide changes to mortgage documents.

Enacted as Public Law 119-101, the Act addresses housing supply, affordability, access to mortgage credit, manufactured and rural housing, veterans housing, and federal housing-program reform. Some provisions amend existing law directly, while others require regulations, orders, forms, studies, or agency guidance. Implementation dates will therefore vary by provision.

For mortgage lenders, two provisions have the clearest borrower-facing document implications: forthcoming revisions to the Uniform Residential Loan Application (URLA) and expansion of the FHA Informed Consumer Choice Disclosure to include a VA loan comparison. Neither change is ready for lender implementation. Lenders should continue using current forms while monitoring guidance from the responsible agencies and government-sponsored enterprises.

Implementation Will Occur Over Time

The Act spans 12 titles and 60 sections and assigns responsibilities to multiple federal agencies and entities, including the Department of Housing and Urban Development (HUD), Federal Housing Administration (FHA), Federal Housing Finance Agency (FHFA), Department of Veterans Affairs (VA), Department of Agriculture (USDA), Consumer Financial Protection Bureau (CFPB), Fannie Mae, and Freddie Mac.

Many provisions will not become operational until the assigned agency issues implementing instructions. Lenders should distinguish requirements established by the statute from requirements that depend on a later order, regulation, form revision, handbook update, or effective-date announcement.

From a document perspective, Sections 601 and 603 identify changes that will affect familiar application and disclosure processes once implementation is complete.

URLA Military Service Question and Disclosure

Section 601 requires FHFA to direct Fannie Mae and Freddie Mac to revise the URLA. The revised form must add a disclosure immediately below the military service question informing an applicant who answers “Yes” that the applicant may qualify for a VA home loan and should consult the lender regarding eligibility.

The military service question must appear above the applicant’s signature line and provide three response options:

• Yes
• No
• Prefer Not to Answer

The new disclosure is intended to increase awareness of potential VA financing. It does not establish that an applicant is eligible for a VA loan.

Section 601 requires FHFA to issue its implementing order within six months after enactment. Based on the July 11, 2026, enactment date, that statutory deadline is January 11, 2027. Fannie Mae and Freddie Mac will then need to revise the URLA and announce applicable publication, transition, and mandatory-use dates.

URLA Implementation Considerations

Lenders should not independently revise the URLA before the official form and implementation instructions are released.

Once the revised URLA is released, implementation could affect more than the appearance of the form itself. Lenders may need to evaluate:

• Loan origination system configurations;
• Application and point-of-sale workflows;
• Data fields and mappings associated with military service;
• Electronic document presentation;
• Testing and quality-control procedures; and
• Policies, procedures, and employee training.

Docutech will monitor FHFA, Fannie Mae, and Freddie Mac guidance and evaluate the resulting form, data, configuration, and testing requirements.

VA Comparison in the FHA Informed Consumer Choice Disclosure

Section 603 amends the FHA Informed Consumer Choice Disclosure. The current disclosure assists prospective borrowers in comparing certain costs of an FHA-insured mortgage with those of a comparable conventional mortgage.

The amendment requires the notice to add a comparable loan guaranteed or insured by the VA using prevailing interest rates. The revised notice must provide VA financing as an additional comparison for prospective FHA borrowers.

The Act expressly states that the mortgagee is not required to determine whether the prospective borrower is eligible for each loan included in the notice. Accordingly, the VA comparison is intended to provide standardized comparative information, not to represent that VA financing is available to a particular borrower.

HUD Guidance Is Needed Before Implementation

Section 603 establishes the required VA comparison but does not provide all operational details needed to revise and deliver the disclosure. HUD must determine how the VA comparison will be incorporated into the existing notice and how lenders must calculate and present the required information.

Borrower eligibility and disclosure delivery are separate issues. A mortgagee will not be required to determine VA eligibility for purposes of including the comparison. However, additional HUD guidance is needed to confirm how the current threshold for providing the FHA disclosure will operate after the VA comparison is added.

The current HUD model notice compares FHA and conventional financing and does not include a VA column. Lenders should not omit the future VA comparison based solely on apparent VA ineligibility, but they also should not create their own VA comparison, calculation methodology, or form language before HUD acts.

Industry implementation will depend on HUD guidance addressing:

• Revised disclosure language and format;
• The required comparison and calculation methodology;
• Assumptions for prevailing VA interest rates;
• The effective date and any transition period; and
• Related updates to FHA guidance.

Until HUD issues those instructions, lenders should continue using the disclosure required under current FHA guidance.

Other Provisions to Monitor

The Act contains other provisions that may eventually affect mortgage operations and documentation. For example, federal housing agencies must establish procedures for consumer requests for reconsideration of value or a subsequent appraisal involving a consumer’s principal dwelling. Implementation could affect appraisal workflows, borrower communications, and related documentation.

Provisions involving small-dollar mortgage lending, manufactured housing finance, housing counseling, and federal housing programs may also result in later compliance or operational changes. The nature and timing of any document impact will depend on agency implementation.

What Lenders Should Do Now

Lenders should not make broad document changes based solely on the Act. Instead, they should:

• Continue using the current URLA and FHA Informed Consumer Choice Disclosure;
• Monitor FHFA, Fannie Mae, Freddie Mac, and HUD implementation guidance;
• Identify systems, data mappings, forms, and workflows that may be affected;
• Coordinate compliance, operations, technology, and vendor-management planning; and
• Allow time for configuration, testing, quality control, procedure updates, and training after final requirements are issued.

Implementation dates are likely to vary. Lenders should base production changes on final agency and enterprise instructions rather than anticipated requirements.

Docutech Is Monitoring Implementation

Docutech’s compliance team is monitoring implementation of the ROAD to Housing Act, with particular attention to forthcoming URLA guidance from FHFA, Fannie Mae, and Freddie Mac and disclosure guidance from HUD.

As final requirements are issued, Docutech will evaluate the legal, document, data, configuration, and implementation impacts; make applicable updates; and communicate relevant timing and client considerations.

For now, lenders should continue current practices and prepare to assess the final requirements when the responsible agencies and enterprises complete implementation.