NCLC, CRL and HPC write to urge FHA to consider adjusting the FHA Streamline Refinance program to allow closing costs to be rolled into the principal balance of the new loan. When paired with our recommendations for enhanced borrower protections for the program, this adjustment would enable more borrowers, particularly low-to-moderate income (LMI), Black, and Hispanic households, and FHA to obtain the benefits of a rate and term refinance.