MBA Joint Comment Letter on New York’s Community Reinvestment Act
The national Mortgage Bankers Association (MBA), the Mortgage Bankers Association of NY (MBA of NY), the New York Mortgage Bankers Association (NYMBA),3 and the Empire State Mortgage Bankers Association (ESMBA), appreciate the opportunity to comment on the proposed regulation published in the February 5, 2025 New York State Register (Register) to implement New York’s Community Reinvestment Act (NYCRA) for independent mortgage banks (IMBs). They have reviewed the proposal and note the text of the regulatory language is largely unchanged from the version released during the mid-December 2024 pre-proposal comment period.
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