Resources
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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 Letter to FHFA on 2025-2027 Multifamily Enterprise Housing Goals
MBA comments on FHFA's the proposed rule on the 2025-2027 Multifamily Enterprise Housing Goals for Fannie Mae and Freddie Mac. The Enterprises are required by statute to promote access to mortgage credit throughout the nation and provide assistance to the secondary market to support housing for low- and moderate-income families, and the housing goals are an important component of the framework by which FHFA can measure the Enterprises’ progress.
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MBA Comment Letter on FHFA 2025 Housing Goals
MBA comments on FHFA's proposed rule outlining the 2025 - 2027 housing goals for Fannie Mae and Freddie Mac (the Enterprises). The goals specify benchmark percentages of the Enterprises’ purchases of single-family mortgages serving low- and very-low-income borrowers and other underserved populations and help drive the Enterprises’ efforts to achieve their mission of supporting liquidity for affordable homeownership.
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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.
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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.