Resources
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MBA Comment Letter to HUD on Changes in Branch Office Registration Requirements
The Mortgage Bankers Association (MBA) offers comments in response to the Department of Housing and Urban Development’s proposed rule to revise HUD’s regulations concerning branch office registration requirements.
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MBA Joint Comment Letter to HUD on NSPIRE
MBA writes in response to the United States Department of Housing and Urban Development (“HUD”) request for public review and comment on the proposed National Standards for the Physical Inspection of Real Estate (“NSPIRE”) physical inspection scoring and ranking methodology to implement HUD's final NSPIRE rule for Public Housing and Multifamily Housing programs, including Section 8 Project-Based Rental Assistance (“PBRA”) and other Multifamily assisted housing, Section 202/811 programs, and HUD-insured Multifamily as described in the NSPIRE proposed rule.
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MBA Comment Letter in response to FHA Draft Mortgagee Letter on ADUs
The Mortgage Bankers Association (MBA) and its members appreciate the opportunity to offer comments in response to the Department of Housing and Urban Development’s (HUD) draft mortgagee letter posted to the Federal Housing Administration’s (FHA) Single Family Housing Drafting Table (Drafting Table) concerning the inclusion of rental income generated by an accessory dwelling unit (ADU) as qualifying income when underwriting a borrower.
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MBA Letter to the House Financial Services Committee on the ANS to H.R. 2798, the CFPB Transparency and Accountability Reform Act
Mortgage Bankers Association shares their views on the planned Financial Services Committee markup of Representative Andy Barr’s Amendment in the Nature of a Substitute (ANS) to H.R. 2798, the CFPB Transparency and Accountability Reform Act, scheduled for April 26, 2023.
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MBA Letter in Response to the FHA 203(k) Rehabilitation Mortgage Insurance Program
The Mortgage Bankers Association (MBA) and its members appreciate the opportunity to offer comments in response to the Federal Housing Administration (FHA) request for information concerning barriers to the use of the FHA 203(k) Rehabilitation Mortgage Insurance Program (203(k) program).
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MBA Letter on MILCON-VA appropriations bill for Fiscal Year (FY) 2024
Mortgage Bankers Association (MBA) share views on the Military Construction, Veterans Affairs, and Related Agencies (MILCON-VA) appropriations bill for Fiscal Year (FY) 2024. MBA supports the Veterans Benefits Administration (VBA) FY 2024 request for sufficient resources to ensure that the VA Home Loan Program provides timely loss mitigation assistance to veteran borrowers in need.
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MBA Letter on T-HUD appropriations bill for Fiscal Year (FY) 2024
Mortgage Bankers Association (MBA) shares their views on the real estate finance industry’s priorities within the Transportation, Housing and Urban Development (T-HUD) appropriations bill for Fiscal Year (FY) 2024.
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MBA Letter to FHA on HECM Claim Changes
The Mortgage Bankers Association offers comments to the FHA Info 2023-25, Draft Mortgagee Letter Proposing Modifications to the Home Equity Conversion Mortgage (HECM) Assignment Claim Type 22 Submission Criteria. MBA strongly supports FHA’s proposed changes to HECM Assignment Claim Type 22 and applauds efforts by FHA to improve claims filing procedures to reduce administrative burdens, eliminate complexity and expedite claims payments.
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MBA Letter to CFPB on Registry of Supervised Nonbanks that Use Form Contracts to Impose Terms and Conditions that Seek to Waive or Limit Consumer Legal Protections
The Mortgage Bankers Association (MBA)1 writes to respond to the Consumer Financial Protection Bureau’s (CFPB or The Bureau) proposal requiring nonbanks subject to its supervisory authority to register and report their use of certain terms and conditions in form contracts for consumer financial products and services.
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HUD Section 8 HAP Joint Comment Letter
On behalf of the undersigned organizations, please find our comments on the above-referenced Advanced Notice of Proposed Rulemaking (ANPR). Our collective organizations represent for-profit and non-profit owners, operators, developers, housing cooperatives, property managers, housing agencies and lenders involved in the provision of rental housing, both affordable and conventional.
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MBA Letter to HUD on Housing Assistance Payment Consolidation
The Mortgage Bankers Association (MBA) comments on HUD’s proposal to transition to a single Section 8 regulation and a single Housing Assistance Payment (HAP) contract for its Section 8 project-based rental assistance programs. MBA unfortunately believes the impact of the proposed changes will have a significant negative impact on the supply of these affordable units.
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MBA and NYMBA Comment Letter on Proposed NYDFS Climate Risk Mitigation Guidance
MBA comments on the New York Department of Financial Services’ (NYDFS) Proposed Guidance for New York State-Regulated Banking and Mortgage Institutions Relating to Management of Material Financial Risks from Climate Change.
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MBA Letter to CFPB on Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders
The Mortgage Bankers Association1 (MBA) submits comments on the Consumer Financial Protection Bureau’s (Bureau or CFPB) proposal requiring covered nonbank financial institutions to register with and report to the Bureau when they become subject to certain public local, state, or federal consumer financial protection agency or court orders.
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Real Estate Coalition Letter on Debt Ceiling
As the leading trade organizations representing those that build, finance, sell, and manage U.S. commercial, multifamily, and residential properties, we urge you to work together to take action to raise the statutory debt limit as soon as possible to avoid roiling financial markets and other significant sectors of the American economy unnecessarily. We commend the discussions that have been held between Congress and the White House in this regard.
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Joint Trades Letter in Support of the Death Tax Repeal Act of 2023
Mortgage Bankers Association (MBA) released a joint Trades Letter in Support of the Death Tax Repeal Act of 2023
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MBA Response to SEC Conflicts of Interest Proposal
The Mortgage Bankers Association (MBA)1 appreciates the opportunity to comment on proposed Rule 192 (the “Proposed Rule”)2 under the Securities Act of 1933 (the “Securities Act”). When adopted in its final form by the Securities and Exchange Commission (the “Commission”), Rule 192 will implement Section 27B of the Securities Act (“Section 27B”)3, which prohibits certain material conflicts of interest in securitizations, subject to the exceptions set forth therein.
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MBA, CREFC Response to SEC Conflicts of Interest Proposal
As The Commercial Real Estate Finance Council (“CREFC”) noted in their comment letter to the original version of the rule proposed in 2011, market participants should not create asset-backed securities (“ABS”) transactions designed to default in order to benefit from the default. We are concerned, however, that the Proposed Rule, as currently written, could materially impair the proper functioning of the CRE financing market by inadvertently capturing entities and activities that do not “bet” against the relevant ABS.
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MBA Responds to HUD Section 184 Indian Home Loan Guarantee Program
The Mortgage Bankers Association (MBA)1 and its members offer comments on the Office of Public and Indian Housing’s notice of proposed rulemaking on Strengthening the Section 184 Indian Home Loan Guarantee Program (Section 184 Program).
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MBA Joint Letter on Tax Increases in FY 2024 Budget Proposal
The budget released today continues the Biden administration’s attack on individually- and family-owned businesses and should be strongly opposed by Congress. The more than $4 trillion in tax hikes it proposes target businesses responsible for most of the jobs and growth in this country and come at a time when federal tax collections are at record levels.
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MBA Letter on the House Financial Services Committee’s markup of the ANS to H.R. 1165, the Data Privacy Act of 2023
On behalf of the Mortgage Bankers Association1 (MBA), I am writing to express our views regarding the House Financial Services Committee’s markup of the Amendment in the Nature of a Substitute (ANS) to H.R. 1165, the Data Privacy Act of 2023, scheduled for consideration on February 28, 2023.