Resources
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MBA Letter to FHFA on FHLB RFI
MBA believes this key finding has a direct connection to our longstanding position that FHLB membership should be expanded to mortgage finance companies with a strong and demonstrable connection to the mission of the FHLBank System.
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MBA Joint Trades Letter on the Revitalizing Downtowns and Main Streets Act
The undersigned organizations write in strong support of the Revitalizing Downtowns and Main Streets Act that Representatives Mike Carey and Jimmy Gomez are preparing to introduce. We encourage you to cosponsor and help advance this bipartisan measure that aims to modernize U.S. real estate, create new and affordable housing, and strengthen local communities through a market-based tax incentive for converting older commercial properties to residential use.
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MBA Letter to Treasury and HUD on its Concerns Regarding the Federal Financing Bank (FFB) Risk-Sharing Program
MBA writes to express our concern about the Biden administration’s continued focus on the Federal Financing Bank (FFB) Risk-Sharing Program. The FFB program creates direct and unfair competition with private sector lenders that participate in the Department of Housing and Urban Development’s (HUD) multifamily accelerated processing (MAP) program and may discourage their participation in the market in the future. The Administration should instead focus its efforts to increase supply on changes to the FHA MAP program and allow MAP lenders to access the FFB.
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MBA Joint Trades Letter on Committee Markup of the American Privacy Rights Act
MBA express concerns about the ambiguity of the Gramm-Leach Bliley Act (GLBA) exception provided in the American Privacy Rights Act (APRA) Discussion Draft and advocate for clear language that provide an exception for entities subject to the GLBA.
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MBA Comment Letter on ML for Significant Cybersecurity Incident Reporting Requirements
The Mortgage Bankers Association provides feedback in response to the recent Mortgagee Letter (ML) concerning Significant Cybersecurity Incident reporting requirements. Given the evolving landscape of cybersecurity threats, it is crucial to establish clear, consistent, and practical policies to navigate potential cyberattacks effectively. By doing so, lenders can better safeguard their systems while protecting customers, employees, vendors, counterparties, and agency partners.
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MBA Letter to VA Subcommittee on H.R. 8647, the VA Home Loan Reform Act
Mortgage Bankers Association writes to express the real estate finance industry’s views on the Amendment in the Nature of a Substitute (ANS) to H.R. 8647, the VA Home Loan Reform Act scheduled for markup in the Committee on Veterans’ Affairs’ Economic Opportunity Subcommittee on Thursday, June 27. The bill, as amended, takes an important first step towards providing the Department of Veterans Affairs (VA) and affected homeowners with a solution to resolve delinquencies that other borrowers with government-backed loans already possess. Veterans rightly deserve the same protection and assistance as other homeowners.
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MBA Joint Trade Letter on FY 2025 Ginnie Mae Appropriations
As Congress commences the process of crafting the Fiscal Year (FY) 2025 Transportation and Housing and Urban Development (“T-HUD”) Appropriations bill, we write to express our strong support for full funding of the FY 2025 budget request level of $67 million for salaries and expenses of the Government National Mortgage Association (Ginnie Mae)
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MBA Letter to HUD on NSPIRE Program
MBA writes to the Department of Housing and Urban Development (HUD) to provide written assurance that servicers will not be held accountable for compliance with the new National Standards for the Physical Inspection of Real Estate (NSPIRE) system until it is fully accessible and usable to each participant.
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Written Statement of Karen Kreutziger Powell Chief Executive Officer Flat Branch Home Loans on Behalf of the Mortgage Bankers Association
Karen Kreutziger Powell, Chief Executive Officer at Flat Branch Home Loans, an independent residential mortgage lender licensed in thirty-six states appears in her capacity as a member of MBA’s Residential Board of Governors – and as a former Co-Chair of MBA’s Independent Mortgage Banker (IMB) Executive Council.
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MBA Joint Letter on NFIP Proposed Dwelling Form Changes
In response to FEMA’s recent publication of a notice of proposed rulemaking directed at National Flood Insurance Program and the Homeowner Flood Insurance Form, we wish to express strong support for the modernization of the policy forms, and we respectfully submit the following comments and concerns for consideration by FEMA.
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MBA Joint Trade letter on the Subcommittee on Innovation, Data, and Commerce Markup of Privacy Legislation
The primary privacy and data security consumer protection law for financial institutions is Title V of the Gramm-Leach Bliley Act (GLBA). We support legislation to put in place a national privacy standard, but that standard must recognize the strong privacy and data security standards that are already in place for the financial sector under the GLBA and other financial privacy laws (e.g., the Fair Credit Reporting Act and Right to Financial Privacy Act) and avoid provisions that duplicate or are inconsistent with those laws.
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MBA Comment Letter on the American Privacy Rights Act of 2024 (“APRA”) Markup
Mortgage Bankers Association appreciates this opportunity to comment on the most recent text of the American Privacy Rights Act of 2024 (“APRA”). MBA has concerns with a number of provisions included in the bill (as currently proposed). Therefore, we respectfully urge your Subcommittee (and, in turn, the full Committee) to carefully consider these concerns as the APRA proceeds to an initial markup later this week.
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MBA Comment Letter to FHFA on Freddie Mac’s Proposed Purchase of Single-Family Closed-End Second Mortgages
The Mortgage Bankers Association1 (MBA) thanks the Federal Housing Finance Agency (FHFA) for the opportunity to comment on a new product proposal2 from Freddie Mac which would allow them to purchase certain closed-end second mortgages. To ensure this new product addresses mission-related needs in the market and does not supplant existing similar offerings or cause unintended market disruption, MBA recommends that FHFA address the outstanding questions before rendering a decision on product approval.
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MBA Joint Letter to the White House on Deputy Secretary Adrianne Todman's Nomination for HUD Secretary
The undersigned national real estate associations represent a broad coalition of housing providers that are committed to working together with policymakers and the Administration to address America’s housing affordability crisis. We write to offer our strong recommendation to nominate Deputy Secretary Adrianne Todman for Secretary of the U.S. Department Housing and Urban Development (HUD).
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MBA Joint Letter to FHFA on Building Energy Codes
The undersigned national real estate associations represent a broad coalition of housing providers that are committed to working together with the Federal Housing Finance Agency (FHFA) to bolster housing supply and address America’s housing affordability crisis. We share in FHFA’s goals of financing high-performing energy efficient and quality homes nationwide, but urge against any proposals to attach specific building code requirements to new construction. We urge you to consider the impacts of new requirements for financing on housing production and instead support voluntary efforts that promote energy efficiency without exacerbating America’s acute housing challenges.
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MBA, CREFC Letter to SEC on CMBS Compliance Documentation
The signed organizations appreciate the time spent on January 25, 2024 clarifying questions with respect to the letter of October 12, 2023 (the “October Letter”) regarding Compliance & Disclosure Interpretation 111.01, Form SF-3 Eligibility Requirements, Timely Transaction Documents (the “C&DI”) published on August 30, 2023 by the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC” or the “Commission”). Responses have been set forth to the Division’s questions below, commencing with Section II, by first restating the understanding as to the Division’s questions and following with responses.
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MBA Letter on Real Estate Finance Bills for HFSC Markup
Mortgage Bankers Association writes to share the association’s views regarding several bills that directly impact the real estate finance system and are scheduled for markup today by the full Financial Services Committee.
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MBA Joint Trades Multifamily Letter on 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 the committee to pass the bipartisan Yes in My Backyard (YIMBY) Act (H.R. 3507), as introduced by Congressmen Mike Flood (R-NE) and Derek Kilmer (D-WA), during the May 16, 2024 House Financial Services Committee markup.
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MBA/Up for Growth Joint Trades Letter on H.R. 3507, the Yes in My Backyard (YIMBY) Act
The listed organizations are proud to support H.R. 3507, the Yes in My Backyard (YIMBY) Act, as it heads to markup in the House Financial Services Committee. This bipartisan legislation is vital for encouraging communities to build more affordable and market-rate housing. The YIMBY Act, which passed the House without opposition in 2020, represents a major step toward restoring balance to the country’s housing ecosystem while also creating more opportunities for Americans and their families to access and afford a home of their own.
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MBA Letter to FHFA on the Servicing Policy Development Process
To improve the deployment of effective mortgage servicing policy to borrowers, the Mortgage Bankers Association (MBA) requests that FHFA and the Enterprises create a process for mortgage servicers to evaluate written drafts of proposed guidance for instances where the Enterprises seek alignment. Greater transparency in the policy development process allows stakeholders to provide insights into the practical application of proposed policy changes before new guidance becomes effective.