Resources
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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.
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MBA Joint Trades Letter on H.R. 3507, the Yes in My Backyard (YIMBY) Act
The following 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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Joint Trade Letter to FHFA on the VantageScore 4.0 Historical Dataset
The following trade groups are writing in advance of the publication of the VantageScore 4.0 historical dataset that the Federal Housing Finance Agency (FHFA) announced plans to release early in the 3rd quarter of 2024. Based on our understanding of what Fannie Mae and Freddie Mac (the GSEs) anticipate including in the release, our members have expressed concerns that the information will be insufficient to meet their data analytics needs.
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MBA Letter to VA on VASP Implementation
The Mortgage Bankers Association (MBA) and Housing Policy Council (HPC) welcome the Department of Veterans Affairs (VA) recent announcement of the Veterans Affairs Servicing Purchase (VASP) program, including the VA’s recognition that servicers require sufficient time to implement the program. Mortgage servicers are committed to the successful launch and long-term viability of the VASP program and realize its potential to help struggling Veterans. Achieving these goals and setting up an effective VASP program will require all stakeholders to execute a complex loss mitigation and servicing transfer process. We are concerned with the lack of information and guidance on how to do so.
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MBA Letter to HUD on FY25 Budget Request
MBA supports providing the Federal Housing Administration (FHA) with the resources it requires, both in staffing and systems upgrades, to maintain its countercyclical role as a government-backed mortgage insurer. Accordingly, MBA has long been a proponent of funding for staffing, project management, and potential improvements that would allow the agency to better manage its operations and the risks associated with its Mutual Mortgage Insurance (MMI) Fund. Therefore, we urge the committee to provide $155 million for FHA’s MMI Program Account, as requested by HUD within President Biden’s FY 2025 budget.
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Housing Affordability Coalition Congressional Letter
Today, a broad coalition of groups representing America’s housing providers, lenders and residents sent members of Congress and the Biden administration a letter outlining a number of bipartisan policies they can undertake that will expand housing supply while lowering costs as they improve housing equity and opportunity.
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Written Statement of Jeffrey Weidell, Northmarq CEO, on U.S. House of Representatives House Committee on Oversight & Accountability Subcommittee on Health Care & Financial Services
In the written statement and through Weidell's remarks, he will provide an overview of the commercial/multifamily real estate sector, a “snapshot” of its current economic landscape, and details regarding immediate actions Congress and regulators can take – or avoid – to encourage sustainable development that ensures the continued strength of this vital portion of the American economy.