Consumer Federation of America, the Center for American Progress, and the National Consumer Law Center appreciate the opportunity to comment on the proposed changes to the Federal Housing Administration (FHA) loan-level lender certification. The lender certification form is important to us because of the critical role that FHA lending plays to facilitate homeownership for the many creditworthy borrowers who find themselves locked out of the conventional market. It is especially important for those families who cannot afford a 20 percent down payment, many of whom are first-time homebuyers and homebuyers of color.