Feedback Wanted: CFPB to Discuss Rental Assistance with Landlords

By Erin Stackley, Esq.
Sr. Policy Representative, Commercial Issues
National Association of REALTORS®

On July 15, 2021, National Association of REALTORS® (NAR) and Institute of Real Estate Management (IREM) staff spoke with representatives from the Consumer Financial Protection Bureau (CFPB) and U.S. Department of the Treasury regarding outreach to landlords about the emergency rental assistance program.

CFPB has a new landlord-focused content page, and they are actively seeking ways to reach out to landlords who are unaware that rental assistance is available or that in many areas they can apply on behalf of tenants.

Communicating with small “mom-and-pop” landlords has been especially challenging, as they are less likely to have contact with the federal government or participate in aid programs generally.

NAR and IREM are exploring ways to collaborate with the CFPB to get their messaging out. One suggestion was that NAR members can share information about rental assistance with their clients who own residential rental properties.

In that situation, the CFPB would create a letter/document that can be easily shared with these clients. This could not only help property owners collect back-rent and keep their tenants from being evicted, but also serve as another way that REALTORS® go above and beyond as valuable resources for their clientele and their communities.

The discussion allowed NAR and IREM to raise several important points, including:

  • The outreach and resources both NAR and IREM have already done and continue to do with our membership about the Emergency Rental Assistance Program (“ERAP”);
  • The need for area-specific information on ERAP programs being communicated – not directing to a federal page where someone then has to dig through several layers of redirects until they get to finally the application for their zip code.
  • Including information for landlords with communications to tenants, so a tenant who wants to participate in the program can provide something official and landlord-directed to their housing provider.
  • Changing the language around the program to appeal more broadly: many people associate the “Emergency Rental Assistance Program” with the eviction moratorium, and may mistakenly believe that when the latter ends, so does the former. There will also be people who are wary of interacting with a federal program. Changing the language to something more neutral and general may attract more people to apply.
  • More direct outreach to smaller property owners. IREM’s data indicates that Class A apartment complex owners are aware of the program; Class B and C are much less likely to know aid is available.
  • The CFPB needs to establish itself as an agency there to help landlords, and not just one looking out for tenants. They need to adjust their language/outreach to landlords to make it explicit that these resources are there for them – carrot, not stick.
  • Try sending out communications on rental assistance that cross-over with populations who received pandemic unemployment, stimulus checks, and even PPP loans, as that indicates they were financially impacted by COVID and thus are more likely to be in need of rental assistance.

NAR and IREM will have a follow-up call with the CFPB in the next couple of weeks to provide more feedback; if you have any to share, please reach out to me and let me know!

We are especially interested in hearing from members who have personally gone through the Emergency Rental Assistance Program application in their state/area.
What were the worst pain points in the application process itself?
Where are there areas that can be improved?
What was good about your application that could be replicated by other states/localities in their programs?

Thank you in advance for your critical feedback.