Resources
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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.
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MBA Letter to the CFPB on the CFPB’s Regulation X
MBA welcomes the opportunity to comment on the Consumer Financial Protection Bureau's (the Bureau) notice of proposed rulemaking (NPRM) Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties (the Proposal). The Proposal significantly changes the mortgage servicing provisions of Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA), and discusses new possible obligations for serving borrowers with limited English proficiency. While we appreciate the Bureau's decision to modernize Regulation X's loss mitigation framework to align with existing practices, the Bureau should amend the Proposal to motivate borrowers to contact their servicers and pursue loss mitigation assistance as early in the delinquency as possible.
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MBA Joint Letter on LEP to CFPB Regarding Regulation X Proposal
The undersigned associations are writing to encourage the Bureau to consider, as part of the proposed Regulation X mortgage servicing rule, practical ways to provide language assistance to borrowers with limited English proficiency (“LEP”).
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MBA Letter to HUD Requesting Federal Flood Risk Management Standard (FFRMS) Extension
MBA Letter sent a letter, signed by more than 30 MAP lenders and service providers, to HUD asking to push back the effective date of the Federal Flood Risk Management Standard (FFRMS). The rule is set to go into effect for FHA Multifamily applications and pre-applications submitted after September 1, 2024.
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MBA Comment Letter on FHA Appendix 8.0 FHA Defect Taxonomy for Servicing Loan Reviews
MBA comments on the Federal Housing Administration’s (FHA) proposed Appendix 8.0 FHA Defect Taxonomy for Servicing Loan Reviews. A Defect Taxonomy addresses loan-level defects or noncompliance with FHA’s Single-Family Housing policies. FHA’s framework must consistently categorize defects and apply the appropriate remedy to become a predictable and effective tool.
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MBA, HPC Letter to VA on VASP Implementation Extension Request
Mortgage Bankers Association (MBA) and Housing Policy Council (HPC) request that the Department of Veterans Affairs (VA) extend the mandatory compliance date for the Veterans Affairs Servicing Purchase program (VASP) to December 31, 2024. Given the complexity of the program and the ongoing policy changes and clarifications published as recently as last week, we believe additional time is necessary for mortgage servicers to successfully update their processes to implement VASP.
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MBA Letter to HUD to Roll Back the Debt Service Coverage Ratio
The undersigned organizations represent FHA multifamily housing providers, lenders, and developers. HUD’s multifamily production levels have significantly declined in recent years. Between FY 2022 and FY 2023, volume dropped by 58%. Based on production data through May 2024, MAP loan volume is expected to decrease by an additional 29.75%. While interest rates are certainly a factor, the fees and requirements of FHA multifamily insured loans also play a role.
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MBA Letter to CFPB on Comment Period Extension for Delaying Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders
MBA Letter to CFPB on Comment Period Extension for Delaying Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders
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MBA Joint Trade Letter to HUD on Section 232 Properties
The Healthcare Mortgagee Advisory Council (HMAC), its Section 232 lender members, the MBA and trade groups representing the nursing home and senior living industry, would like to acknowledge the highly valued partnership we have had with HUD since the creation of the 232 program. It is because of this history of partnership that we want to bring to your attention an issue causing great concern for Section 232 lenders and for the industry partners jointly signing this letter.
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MBA Joint Letter on California AI Bill
MBA Joint Letter on California AI Bill
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MBA Comment Letter to CFPB on Mortgage Closing Costs RFI
The Mortgage Bankers Association (MBA) appreciates the opportunity to respond to the Consumer Financial Protection Bureau’s (CFPB or Bureau) request for information (RFI) regarding fees imposed in residential mortgage transactions. Promoting affordable and sustainable homeownership and removing barriers to homeownership is a shared goal of MBA and the CFPB. However, the Bureau’s focus on mortgage closing costs is misguided and inaccurately characterizes certain disclosed, required and necessary mortgage-related fees as “junk fees” in its press releases, blogs, circulars, advisory opinions, and public speeches. These statements suggest that the CFPB may have already arrived at predetermined conclusions about the questions in this RFI and the validity of these charges.
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MBA Joint Trades Letter on the CFPB’s RFI on Mortgage Closing Costs
The Associations support the Bureau’s interest in understanding the affordability challenges facing the housing market. It is regrettable that the CFPB is inaccurately characterizing certain fully disclosed, statutorily required and necessary mortgage-related fees as “junk fees” through blogs, circulars, advisory opinions, and public speeches. It is damaging for consumers and industry stakeholders alike to have the principal consumer financial protection regulator mischaracterize legitimate and fully disclosed fees associated with products and services that are of crucial financial utility and serve critical risk management purposes.
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MBA Joint Letter to Ginnie Mae on Proposed HMBS 2.0 Term Sheet
National Reverse Mortgage Lenders Association and the Mortgage Bankers Association (the “Associations”) write to commend Ginnie Mae’s efforts to boost liquidity for HECM issuers and emphasizes key recommendations to streamline processes, reduce costs, and ensure operation efficiency.
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MBA Joint Letter on H.R. 8127, The Heirs Estate Inheritance Resolution and Succession (HEIRS) Act of 2024.
The undersigned organizations, write to express our strong support for H.R. 8127, The Heirs Estate Inheritance Resolution and Succession (HEIRS) Act of 2024. This bipartisan legislation will provide relief to the countless families across the country that are negatively impacted by heirs’ property.
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MBA Comment Letter on Proposed 2025 NMLS Fee Changes
The Mortgage Bankers Association (MBA) appreciates the opportunity to provide comments to the Conference of State Bank Supervisors (CSBS) and State Regulatory Registry, LLC (SRR) in response to the proposed 2025 National Multistate Licensing System (NMLS) Fee Changes.