Resources
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
MBA Joint Letter to House on Committee Markup of the H.R. 7890
-
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).
-
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.
-
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.
-
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.
-
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.
-
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”).
-
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.
-
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.
-
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.
-
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.
-
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
-
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.
-
MBA Joint Letter on California AI Bill
MBA Joint Letter on California AI Bill