Resources
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MBA Letter to FHA on Permanent Loss Mitigation Waterfall
The Mortgage Bankers Association appreciates the efforts of the Federal Housing Administration (FHA) to engage with the industry to craft effective loss mitigation guidance to protect borrowers from foreclosure, especially the recently announced Payment Supplement program. As you know, access to the FHA’s COVID-19 Recovery Loss Mitigation Waterfall (“COVID waterfall”) will expire on April 30, 2025. MBA believes that maintaining the flexibility available to distressed borrowers throughout the pandemic is essential to preserving affordable homeownership for future borrowers and the health of the Insurance Fund.
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MBA-Led Coalition Letter to SBC and HFSC on Trigger Leads Legislation
The undersigned groups, representing a diverse set of housing and financial services stakeholders and advocates, are writing to express our strong support for the bicameral, bipartisan Homebuyers Privacy Protection Act of 2024, as introduced by Senators Jack Reed (D-RI) and Bill Hagerty (R-TN) and Representatives John Rose (R-TN) and Ritchie Torres (D-NY). This important consumer protection legislation, S. 3502, and H.R. 7297 (respectively), if enacted, would curb the abusive use of mortgage credit “triggers leads” in all but a limited set of circumstances. We urge you to support this carefully crafted proposal and to schedule the two bills for markup before your respective committees as soon as possible.
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MBA Joint Trades Letter on Biden Administration Fact Sheets on Housing Supply
The undersigned national real estate and housing associations represent abroad coalition of housing providers and lenders that are committed to working together with policymakers to promote sustainable and responsible solutions to address America’s housing availability and affordability challenges. Today, we offer this letter in response to the Administration’s recent Fact Sheets, “Biden-Harris Administration Announces New Actions to Boost Housing Supply and Lower Housing Costs,” and "The Price Isn’t Right: How Junk Fees Cost Consumers and Undermine Competition.
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MBA Letter on Re-Proposed Illinois CRA Rules to the Department and Legislative Staff
The Mortgage Bankers Association (MBA) appreciates the opportunity to again provide comments to the Illinois Department of Financial and Professional Regulation (IDFPR) on the implementation of Public Law 101-657 of 2021, the Illinois Community Reinvestment Act (ILCRA). MBA and our member companies are committed to providing fair and equitable access to credit, and they continue to work with government and private sector stakeholders to develop new products and strategies to reach underserved markets and communities. MBA also appreciates IDFPR’s extension of the comment period until March 6th as well as the opportunity to discuss MBA member views during a recent meeting.
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MBA Letter on House Financial Services Committee Housing Bills Markup
Mortgage Bankers Association is writing to share the association’s views regarding two of the bills that impact the real estate finance system scheduled for markup by the full Financial Services Committee on February 29, 2024.
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MBA Statement on Automated Valuation Models and Property Data Collection
The Mortgage Bankers Association appreciates the opportunity to participate in today’s working session to educate this group on the use of algorithm technology in the mortgage process and specifically the use of automated valuation models (AVMs) and property data collectors. The mortgage industry has carefully and deliberately introduced AI, algorithms, and other technologies for a number of reasons, including increasing efficiency, lowering the risk of human error and improving consumer experience.
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MBA Letter to VA on the Veterans Housing Stability Act of 2024
Mortgage Bankers Association writes to express support for S. 3728, the Veterans Housing Stability Act of 2024. According to the MBA National Delinquency Survey, 74,370 Veterans are seriously delinquent on their home mortgages as of December 31, 2023. The bill provides these homeowners – who earned their Department of Veterans Affairs (VA) loan guarantee through sacrifice and service to our nation – a solution to resolve delinquency that other borrowers with government-backed loans already possess.
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MBA Joint Comment Letter on Proposed Changes to Rule 3002.1
Founded in 1988, the USFN - America's Mortgage Banking Attorneys® ("USFN") is a national, not-for-profit association of law firms that specialize in matters of real estate finance. USFN consists of law firms that represent banks, mortgage lenders, mortgage servicing companies and government sponsored enterprises in connection with foreclosure, bankruptcy, loan modifications and other workouts, inventoried properties, and litigation related to these areas of representation. Membership also includes industry-affiliated suppliers of products and services.
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MBA Comment Letter on Proposed Changes to Bankruptcy Rule 3002.1
The Mortgage Bankers Association (MBA)1 offers the following comments in response to the proposed changes to Bankruptcy Rule 3002.1 and its associated forms by the Judicial Conference of the United States (the Conference).
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MBA Letter to Treasury on FSOC Concerns About Nonbank Mortgage Servicers
The Mortgage Bankers Association writes in response to certain comments you made regarding independent mortgage bankers (IMBs) during last week’s hearings on the Financial Stability Oversight Council (FSOC)’s Annual Report to Congress.
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MBA Comment Letter to VA on Minimum Property Requirements ANPR
The Mortgage Bankers Association (MBA) appreciates the opportunity to provide comments in response to the Department of Veterans Affairs (VA) Advance Notice of Proposed Rule Making (ANPR) concerning the need for improvements to VA’s minimum property requirements (MPRs) for the VA-guaranteed and direct loans as required by the Improving Access to the VA Home Loan Benefit Act of 2022. The VA Home Loan Guaranty Program is one of the most significant benefits servicemembers and veterans receive in return for their sacrifice, and making this program more accessible and operationally efficient is a critical step towards delivering much needed housing to our nation’s heroes. At a time when inventory remains historically low and the average purchase price for a new home has reached $492,3002, it is imperative to ensure that the VA Home Loan Guaranty program remains competitive and viable for veterans or service members.
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MBA Joint Letter to NY Legislative Leaders on the 421a Program
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MBA Joint Letter to HUD on Section 8 Income Limits
MBA signed a coalition letter responding to HUD’s proposed rule on calculating Section 8 income limits. The letter expresses concern with the new methodology and the negative impact on Fair Market Rents, which in can make it challenging to predict and plan for the costs of construction and maintenance of affordable housing.
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MBA Letter to Federal Trade Commission on Unfair or Deceptive Fees
The undersigned organizations appreciate the Federal Communications Commission’s (“Commission”) efforts to clarify rules regarding revocation of consent. As we have previously explained, the members of the Associations make every effort to promptly honor reasonably relayed requests to stop further communications.
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MBA Letter to the FTC on Trade Regulation Rule on Unfair or Deceptive Fees
The Mortgage Bankers Association and its members appreciate the opportunity to offer comments on the Federal Trade Commission’s (FTC’s) Notice of Proposed Rulemaking regarding Unfair or Deceptive Fees. The MBA shares the FTC’s commitment to transparent pricing of consumer goods and services, but mortgage lending is already subject to comprehensive disclosure rules, known as Regulation Z, promulgated by the Consumer Financial Protection Bureau (CFPB) under the Truth in Lending Act (TILA), as well as a broad regulatory prohibition, in the CFPB’s Regulation N, on making misrepresentations in relation to a mortgage transaction.
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MBA Letter to FCC on Revocation of Consent under the Telephone Consumer Protect Act
The Mortgage Bankers Association and its members appreciate the opportunity to offer comments on the Federal Trade Commission’s (FTC’s) Notice of Proposed Rulemaking regarding Unfair or Deceptive Fees.2 The MBA shares the FTC’s commitment to transparent pricing of consumer goods and services, but mortgage lending is already subject to comprehensive disclosure rules, known as Regulation Z, promulgated by the Consumer Financial Protection Bureau (CFPB) under the Truth in Lending Act (TILA), as well as a broad regulatory prohibition, in the CFPB’s Regulation N, on making misrepresentations in relation to a mortgage transaction.
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MBA Joint Letter to Governor Hochul Supporting 421a Program
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MBA Letter on H.R. 7024 Floor Vote
Mortgage Bankers Association writes to express the staunch support for H.R. 7024, the “Tax Relief for American Families and Workers Act of 2024,” which is scheduled to be considered by the full U.S. House of Representatives under suspension of the rules today.
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MBA Joint Comment Letter in Support of H.R. 7024, the “Tax Relief for American Families and Workers Act of 2024”
The undersigned real estate trade associations write to express our strong support for H.R. 7024, The Tax Relief for American Families and Workers Act of 2024 (the “Act”). We urge you to vote in favor of this legislation when it is considered by the full House of Representatives. The bill, which the Committee on Ways and Means approved by an overwhelming bipartisan 40-3 vote on January 19, would increase the availability of Low-Income Housing Tax Credits (LIHTC) to spur the production of more critically needed affordable housing units, as well as suspend certain tax increases on business investment that took effect in 2022 and 2023. The passage of H.R. 7024 will help increase the supply of housing across the country and have a positive impact on the housing affordability crisis.
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MBA Letter to Congressional Leaders on H.R. 3335, the IRS eIVES Modernization and Anti-Fraud Act of 2023
As the leading organizations representing virtually all of the financial services industry, we write to share our concerns about recent policy changes announced by the Internal Revenue Service (IRS) regarding the Income Verification Express Service (IVES) and urge you to pass H.R. 3335, the IRS eIVES Modernization and Anti-Fraud Act of 2023 to ensure the IRS follows the original intent of Congress and prevents disruptions to the consumer and commercial lending industries.