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58 EMERGENCY PROTECTIONS NO LON- GER NEEDED e pandemic-triggered foreclosure morato- rium expired in June 2021, although it was effec- tively extended through the end of the year by a temporary mortgage servicing rule adopted by the Consumer Financial Protection Bureau (CFPB). Foreclosure completions did not surge once the moratorium ended, an indication that poli- cymakers were wise to phase out this emergency foreclosure prevention measure when they did. Foreclosure completions have gradually increased in 2022, but through the first three quarters are still less than 50% of pre-pandemic levels, accord- ing to data from Auction.com (a platform that accounts for nearly half of all foreclosure auctions nationwide). e forbearance program will be in effect at least until the COVID-19 National Emergency is officially over, but a relatively few borrowers continue to enter forbearance—less than 10,000 a month compared to a total of more than eight million that have ever entered over the lifetime of the program, according to data from Black Knight. In an Urban Institute report titled "Normal- izing Forbearance," Laurie Goodman and co-au- thors Alexei Alexandrov and Ted Tozer argue that the blanket, no-documentation and long- term payment pause features of the COVID-19 forbearance program are not necessary or prudent outside of national emergencies. "In the case of a national emergency, 12 to 18 months I think is totally appropriate. In the case of normal, day-to-day, I think it's a long period of time," said Goodman, referring to the maximum length of mortgage payment pause allowed under the COVID-19 forbearance. Goodman and her co-authors propose limiting the payment pause to four months. ey also propose limiting forbearance to a targeted set of four borrower circumstances—job loss, death of co-borrower, divorce, or a qualifying health event—and requiring documentation of those circumstances from borrowers. e proposed non-emergency forbearance framework stems not only from lessons learned from the pandemic forbearance but also lessons learned during the Great Financial crisis and from natural disasters that have occurred in the last decade "I think you have to think of the COVID forbearance program as evolving from HAMP, the original Great Financial Crisis loss mitigation product," Goodman said. "We moved to stream- lined modifications. And then a series of natural disasters sort of forced the expansion of the program. at became the pandemic playbook, basically what was used for natural disasters." e natural disaster playbook typically involved a relatively short foreclosure moratorium in the immediate aftermath of the emergency followed by more focused forbearance and loss mitigation. is playbook helped markets impact- ed by natural disasters to avoid the unintended negative consequences of a lengthy blanket fore- closure moratorium that some states experienced following the Great Financial Crisis. "Lengthy, blanket foreclosure moratoria often only serve to kick the foreclosure can down the road rather than addressing the root issues that can help prevent foreclosure," said Ali Haralson, President of Auction.com. "is blanket approach ends up hurting more than helping in the long run, particularly in a sluggish housing market where home prices are flatlining or falling. In the wake of the Great Recession, states employing this approach tend- ed to be where so-called zombie foreclosures became most prevalent and where home prices took the longest to bounce back." In his role as VP of Market Economics, Auction.com, Daren Blomquist analyzes and forecasts complex macro- and microeconomic data trends within the marketplace and greater industry to provide value to both buyers and sellers using the Auction.com platform. Blomquist's reports and analysis have been cited by thousands of media outlets nationwide—in- cluding the Wall Street Journal, the New York Times, USA TODAY, and on many national network broadcasts, including CBS, ABC, CNN, CNBC, FOX Business, and Bloomberg. Feature By Daren Blomquist