Resources
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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.
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MBA Joint Trade Letter Opposing President Joe Biden's Rent Control Proposal
The undersigned national real estate associations write to share our strong opposition to your recent proposal to cap rents nationwide. Rent control policies have proven time and again to increase rents, reduce the capital needed to boost the supply of housing, and ultimately hurt renters today and in the future.
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MBA Letter to VA Requesting a Delay on Loan Review API
MBA members support the recent initiatives of the VA Loan Guaranty Service to implement systems that streamline and improve the mortgage origination process, however, whenever such changes are made it is essential that the VA allows sufficient time for testing, troubleshooting and system integration.
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MBA Joint Letter to CFPB Requesting Reg X Extension
The undersigned associations and organizations submit this joint letter to seek an extension of the deadline for submission of comments on the Bureau's proposed amendments to Regulation X.
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MBA Letter to FHA and HUD Requesting ROV extension
MBA submitted a letter to FHA and HUD on the extension on the implementation Reconsideration of Value Policy.
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MBA Joint Letter to HUD on FFRMS Extension
The undersigned national real estate associations represent a broad coalition of housing providers committed to working with the Department of Housing and Urban Development (HUD) to bolster housing supply and address America’s housing affordability crisis. We share in HUD’s goals of resiliency and efforts to combat the impact of climate change on real estate, especially housing. However, our groups have significant concerns about the implementation of the recent Federal Flood Risk Management Standard (FFRMS) rule. FHA Multifamily borrowers must not be subject to an implementation date that is arbitrary and impacted by the capacity of HUD staff.
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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.