Resources
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MBA Joint Letter on FHA Servicing Handbook Updates
MBA comment on the Federal Housing Administration’s (FHA) proposal to update the Servicing and Loss Mitigation, Claims, and Dispositions sections and Appendix 4.0 of the Single-Family Housing Policy Handbook.
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MBA Industry Comment on FHA Loss Mitigation Updates
MBA comments on joint policy recommendations in response to FHA’s November 25, 2024 draft handbook. Our recommendations demonstrate strong support for HUD’s draft and alignment on significant points related to the loss mitigation process.
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MBA Letter on Illinois Mortgage CRA Examination Fee Implementation
The Mortgage Bankers Association (MBA) is writing to express urgent concern regarding the January 1, 2025 due date for annual fees its independent mortgage bank (IMB) members are expected to pay to implement the Illinois Community Reinvestment Act (ILCRA). Because the new fee structure was only published in the Illinois Register on December 6th, MBA strongly urges the Illinois Department of Financial and Professional Regulation (IDFPR) to provide licensees at least a 60-day grace period for payment.
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MBA Letter to FHA Advocating for Modernized Title I Loan Process
The Mortgage Bankers Association (MBA) appreciates the opportunity to comment on the Federal Housing Administration’s (FHA) draft Title I Letter (TIL) regarding the proposal to modernize the Title I loan application process by replacing outdated forms (HUD-56001 and HUD-56001-MH) with the industry-standard Uniform Residential Loan Application (URLA, Fannie Mae Form 1003/Freddie Mac Form 65), along with the introduction of a new HUD Addendum for Title I Loans (HUD-92900-TI).
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MBA Letter to HUD on Draft Mortgagee Letter Concerning Boarder Income
MBA Letter to HUD on Draft Mortgagee Letter Concerning Boarder Income
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MBA Joint Letter to Congress on Road to Housing Act
The undersigned organizations – whose members all play a critical role in the production, financing, sale, and rental of both single- and multifamily housing throughout the country –support the Renewing Opportunity in the American Dream to Housing Act (“ROAD to Housing Act,” S. 5027/H.R. 990), authored by Senator Tim Scott (R-SC) and Representative French Hill (R-AR).
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MBA Joint Support Letter for H.R. 3507, the Yes In My Backyard (“YIMBY”) Act
The undersigned national associations represent for-profit and non-profit owners, operators, developers, lenders, property managers, housing agencies, housing cooperatives and advocacy organizations involved in the provision and promotion of housing, both affordable and conventional. We are writing to urge Members of the House of Representatives to pass the bipartisan Yes in My Backyard (YIMBY) Act (H.R. 3507), sponsored by Congressmen Mike Flood (R-NE) and Derek Kilmer (D-WA), during House consideration this week.
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MBA Letter on HUD's Mortgagee Review Board Enforcement Against Convenience Fees
MBA understands that numerous mortgage servicers have received notices of violation (NOV) from the Department of Housing and Urban Development’s (HUD) Mortgagee Review Board (MRB) alleging that they violated HUD requirements by charging borrowers convenience fees for the borrowers’ use of optional expedited payment services. Specifically, HUD, through the NOVs, contends that accepting and processing borrowers’ mortgage payments online, over the phone through a customer service representative, or through interactive voice recognition is “part of a prudent Mortgagee’s servicing activity” and, therefore, charging a fee for such activity is prohibited. MBA disagree with HUD’s conclusions and express concern with HUD’s administrative enforcement efforts. Accordingly, MBA urge HUD to rescind the pending NOVs and cease further MRB action on convenience fees
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MBA Support Letter for H.R. 3507, the Yes In My Backyard (“YIMBY”) Act
Mortgage Bankers Association (MBA) write to reiterate our industry’s support for H.R. 3507, the Yes In My Backyard (“YIMBY”) Act, as amended, when it comes before the full House this week for a floor vote under suspension of the rules. This bipartisan legislation encourages communities to remove barriers that prevent the production of much-needed housing in areas throughout the United States by requiring Community Development Block Grant (CDBG) recipients to report the extent to which they are implementing specific pro-affordability and ant discriminatory housing policies.
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MBA Joint Letter to FHFA on Replacement Cost Value
The American Bankers Association, Housing Policy Council, and Mortgage Bankers Association (the Associations) respectfully request that the Federal Housing Finance Agency (FHFA) direct Fannie Mae and Freddie Mac (the Enterprises or the GSEs) to rescind the bulletins issued in February 2024 regarding property insurance verifications (2024 Bulletins), as well as recall the associated survey currently being conducted for lenders and servicers.
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MBA Comment Letter Urging Updates to GSE Condo Loan Eligibility Guidelines
The Mortgage Bankers Association (MBA) advocates for critical updates to the condominium loan eligibility guidelines established by Fannie Mae and Freddie Mac (the Enterprises). The Federal Housing Finance Agency (FHFA), the Enterprises, and MBA share a common goal of promoting stable and affordable access to financing for this important sector of the housing market.
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MBA Letter to FHA on Partial Claim Document Recording and Payoff Statements
Mortgage Bankers Association expresses our concern regarding the policy guidance proposed by the Federal Housing Administration’s (FHA) draft Mortgagee Letter (ML), Partial Claim Document Recording and Payoff Statements. While MBA recognize and appreciate FHA’s commitment to streamlining loss mitigation processes and improving transparency for borrowers, we are concerned FHA’s proposal to require mortgage servicers to use HUD’s SMART Integrated Portal (SIP) to provide borrowers with a payoff statement for all partial claims -- recorded and unrecorded alike -- creates significant operational and regulatory challenges.
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MBA Letter to HUD on Loan Disbursements
The Mortgage Bankers Association (MBA), and the lenders listed below, respectfully submit these comments on HUD’s proposed rule on disbursing multifamily mortgage proceeds. The proposed rule would allow 1% of mortgage proceeds to be drawn before equity is exhausted. We believe this is insufficient and urge HUD to allow mortgage proceeds to be drawn on any construction draw proportional to the amount of debt relative to total cost. Without this change, the costs of multifamily construction lending through the 221(d)(4), 220, 231 and 213 programs (“Construction Loans”) will continue to be negatively impacted.
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MBA Comment Letter to HUD on Federal Flood Risk Management Standard Extension
The Mortgage Bankers Association (MBA) is writing to reiterate our concern that the Department of Housing and Urban Development’s (HUD) Federal Flood Risk Management Standard (FFRMS) rule remains unready for implementation. The recent events in the Southeast demonstrate the importance of building resiliency, and the safety of residents has never been more evident.
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MBA Joint Letter Urging NFIP Extension
The undersigned organizations urge Congress to act quickly to extend the National Flood Insurance Program (NFIP) before its September 30 expiration. We appreciate that Section 137 of the Continuing Resolution (CR) the full House is poised to consider this week extends NFIP authorities through the duration of the proposed CR and into December.
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MBA Joint Letter to House on Committee Markup of the H.R. 7890
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MBA Comment Letter on New Illinois Fee Structure for IMB CRA Exams
The Mortgage Bankers Association comments in opposition of the proposed fee changes for Illinois state-licensed companies. These proposed changes published by the Department of Financial and Professional Regulation (IDFPR) in the Illinois State Register on August 2, 2024, suggest a new scheme for assessing fees to cover IDFPR’s costs to implement the Illinois Mortgage Community Reinvestment Act (ILCRA).
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MBA Joint Trade Letter on FHA’s Face-to-Face Guidance
The American Bankers Association, Housing Policy Council, Mortgage Bankers Association, and the National Mortgage Servicing Association (the Associations) submit comments on the Draft Mortgagee Letter (ML), Modernization of Engagement of Borrowers in Default.
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MBA Joint Letter to Congress, Administration on Pro-Growth Tax Agenda
The U.S. Chamber of Commerce led 529 chambers and associations—representing every sector of the U.S. economy and all 50 states—in calling on the next Congress and administration to prevent tax increases on American families and businesses and instead protect American paychecks by pursuing a pro-growth agenda that will foster capital investment, job creation, and higher wages.
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MBA Joint Letter on the CFPB’s NPRM on Regulation X
The undersigned associations welcome the opportunity to comment on the CFPB's notice of proposed rulemaking (NPRM) Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties. Collectively, the undersigned associations represent all aspects of the mortgage finance industry, from originators, servicers, securitizers, and whole loan and Mortgage-Backed Securities (MBS) investors and offer our comments in the spirit of serving consumers well in a properly regulated financial services market.