Life Companies and Commercial/Multifamily Lending
Life insurance companies are important sources of capital for commercial and multifamily real estate lending.
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MBA supports the state-based model for insurance regulation and appropriate reductions to the federal regulation of insurance, including SIFI designation and regulation. MBA seeks to preserve or improve on the National Association of Insurance Commissioners (NAIC) regulatory capital regime for CRE mortgages and real estate to support life companies’ investment portfolios across all economic conditions. In addition, MBA also actively advocates for reasonable risk-based capital requirements for insurance companies, where required capital levels are commensurate with risk.
RELATED: Read MBA’s White Paper: Role of Insurance Companies in CRE.
Recent MBA Activity Related to Life Companies and Commercial/Multifamily Lending
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MBA Letter to S&P Global Ratings on Insurer Risk-Based Capital Adequacy
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MBA Joint Letter to NAIC on Practices & Procedures (P&P) Manual Amendment
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MBA and ACLI Comments on CM6 and CM7 RBC Factor Normalization
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MBA Letter to S&P Global Ratings on Risk-Based Capital
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MBA Letter to NAIC on RBC Proposal
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MBA Joint Letter to NAIC on on Mortgage Reporting Guidance Extension
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MBA Joint Letter to CDC on the National Eviction Moratorium
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MBA Joint Letter to NAIC on TDR Relief
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MBA Joint Letter to NAIC on Statutory Accounting INT 20-03 and INT 20-07
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MBA Joint Letter to NAIC Proposed RBC Reporting of 2020 NOI
Related Resources
CARES Act Section 4013
- Text of section 4013 as amended December 29, 2020.
Interagency Statements
- Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus (Revised) (April 7, 2020)
- FASB Statement on Interagency Statement (March 22, 2020).
- FFIEC Joint Statement on Additional Loan Accommodations Related to COVID-19 (Aug. 3, 2020)
NAIC Life RBC and Accounting relief
- COVID-19 RBC Guidance from E Committee (March 27, 2020)
- Q&A on E Committee Guidance (June 12, 2020)
- Additional Guidance for Life RBC (Revised Feb. 11, 2021)
- INT 20-03: Troubled Debt Restructuring Due to COVID-19
- INT 20-07: Troubled Debt Restructuring of Certain Debt Instruments Due to COVID-19
Related MBA Events
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Commercial Real Estate Basics: Introduction to Commercial/Multifamily Real Estate: January 2025: On Demand
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CREF Career Conversations: Insights from Industry Leaders
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Commercial/Multifamily Finance Convention and Expo -
Commercial Real Estate Basics: Borrower Mortgage Credit and Financial Statement Analysis: February 2025
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School of Multifamily Property Inspections: February 2025: Atlanta
