Resources
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MBA Joint Trades Letter Requesting Data Analysis for Credit Scoring Initiative
The undersigned organizations are writing to request that the Federal Housing Finance Agency (FHFA) release the analyses performed by FHFA, Fannie Mae, and Freddie Mac (the Enterprises) to assess various aspects of the credit scoring models – FICO 10T and VantageScore 4.0 – pursuant to the Validation and Approval of Credit Score Models Rule (12 CFR 1254.7) and the criteria stipulated in the Enterprise Credit Score Solicitation, as well as analyses conducted to support the shift to bi-merge reporting.
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MBA Joint Letter on FY 2024 FHA and Ginnie Mae Funding
MBA Joint Letter on FY 2024 FHA and Ginnie Mae Funding
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MBA Joint Trade Letter to VA on VASP Program
On behalf of the clients, communities, companies, and borrowers we serve, MBA is concerned with a key feature of the forthcoming Veterans Assistance Servicing Purchase (VASP) Program. MBA appreciates VA’s work on the program, and agree with the statement that your team filed with OMB, that "the rising rate environment combined with the residual impact of the pandemic has left traditional loss mitigation options insufficient to meet the need of affordable home retention options.
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MBA Comment Letter on FHA’s Payment Supplement Claim Drafted Mortgagee Letter
The Mortgage Bankers Association (MBA) and National Mortgage Servicing Association (the Associations) appreciate the opportunity to comment on the Federal Housing Administration’s (FHA) Draft Mortgagee Letter (Draft ML), the Payment Supplement. Ensuring struggling borrowers have options to avoid foreclosure in high-interest rate environments remains a top priority for mortgage servicers. The Associations agree that an innovative loss mitigation alternative to a traditional loan modification that provides temporary payment relief to FHA’s seriously delinquent borrowers is imperative. Given the complexity of the new Payment Supplement account, we appreciate the opportunity for a second round of stakeholder comments via the drafting table.
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MBA Joint Letter in Support of the Workforce Housing Tax Credit Act
The undersigned national associations represent for-profit and non-profit owners, operators, developers, lenders, property managers, and other real estate professionals, as well as housing cooperatives involved in the provision of rental housing, both affordable and conventional. We are writing to thank you for introducing the Workforce Housing Tax Credit Act to establish a tax credit for workforce housing. Our industry strongly supports this groundbreaking legislation that represents an integral step to address the severe shortage of workforce housing available to millions of this nation’s hardworking families.
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MBA Joint Letter on Yes in My Backyard (YIMBY) Act (H.R. 3507 and S. 1688)
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 express our strong support for the bipartisan Yes in My Backyard Act (YIMBY) as introduced by Senators Brian Schatz (D-HI) and Todd Young (S.1688) and Congressmen Mike Flood (R-NE) and Derek Kilmer (D-WA) (H.R. 3507). We urge your support for this legislation, and for committee consideration as soon as possible.
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Statement for the Record for the HFSC Subcommittee Housing Affordability Hearing
The Mortgage Bankers Association appreciates the opportunity to comment on the issues raised by the Housing and Insurance Subcommittee’s December 6, 2023, legislative hearing entitled, “Housing Affordability: Governmental Barriers and Market-Based Solutions.”
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MBA Recommendation Letter to CFPB to Modernize the Mortgage Servicing Rules of Regulation X
The Mortgage Bankers Association welcomes amendments to the mortgage servicing rules of the Real Estate Settlement Procedures Act and its implementing regulation, Regulation X. We greatly appreciate the Bureau’s recent engagement with MBA. As mentioned, please accept these insights and policy recommendations for the Bureau’s consideration before a proposed rule is published.
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MBA Letter to FHA on Proposed Changes to HECM for Purchase Program
The Mortgage Bankers Association writes to express our strong support for the Federal Housing Administration's (FHA) proposed changes to ensure the stability and broad availability of the Home Equity Conversion Mortgages (HECM) program products in Federal Notice, Home Equity Conversion Mortgage (HECM) HECM for Purchase – Acceptable Monetary Investment Funding Sources and Interested Party Contributions. MBA applauds FHA’s proposal to expand additional funding sources available for borrowers to meet their monetary investment requirement to qualify for an HECM-for-Purchase loan.
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MBA Letter to FHA on Show Me State Premium Homes v. McDonnell (8th Cir. 2023)
The U.S. Court of Appeals for the 8th Circuit recently held in Show Me State Premium Homes v. McDonnell that a subordinate lien (other than a federal tax lien) held by the United States must be foreclosed by judicial action. Today, the Mortgage Bankers Association (MBA) requests immediate guidance from the Federal Housing Administration (FHA) given the high volume of partial claims mortgage servicers completed throughout the COVID-19 pandemic.
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MBA Joint Letter to House and Senate Leadership on Averting Shutdown, Reauthorizing NFIP
The undersigned organizations are encouraged by the headway Congress is making in the appropriations process, and the measures you are considering to ensure the continuity of government operations. That progress is greatly appreciated as the stakes are high. In these challenging economic times, the ability to access and preserve affordable housing opportunities is critical to all Americans. Therefore, our organizations urge you to redouble your efforts and support the ability to pursue the American dream of property ownership and access to quality, rental housing by extending the authority of the National Flood Insurance Program (NFIP) and ensuring other vital housing programs do not lapse on November 17th.
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MBA Letter on HFSC Housing & Insurance Subcommittee Hearing on Property Insurance
The Mortgage Bankers Association (MBA) appreciates the opportunity to provide our perspective regarding the challenges within the property insurance market and their impact on consumers and other issues raised by the Housing and Insurance Subcommittee’s November 2, 2023, hearing entitled, “Factors Influencing the High Cost of Insurance for Consumers.”
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MBA Letter on ONCD RFI on Cyber Regulatory Harmonization
An opportunity to comment on the Office of the National Cyber Director (ONCD) Request for Information (RFI) on cyber regulatory harmonization. MBA members are strong proponents of protecting consumer data. Maintaining up-to-date data security practices remains a top priority for the real estate finance industry.
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MBA Joint Letter to Federal Reserve on Rate Path; MBS Plans
The Mortgage Bankers Association (MBA), National Association of REALTORS® (NAR), and National Association of Home Builders (NAHB) write today to the Board of Governors of the Federal Reserve System (hereinafter “the Fed”) to convey profound concern shared among our collective memberships that ongoing market uncertainty about the Fed’s rate path is contributing to recent interest rate hikes and volatility. This has exacerbated housing affordability and created additional disruptions for a real estate market that is already straining to adjust to a dramatic pullback in both mortgage origination and home sale volume. These market challenges occur amidst a historic shortage of attainable housing.
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MBA Joint Trade Request to Extend the Face-to-Face Waiver
The Housing Policy Council (HPC), Mortgage Bankers Association (MBA), and the National Mortgage Servicing Association (NMSA) (the Associations) recently submitted comments for your consideration, in response to the Department of Housing and Urban Development’s (HUD) proposal to modernize the rules applicable to a Federal Housing Administration-insured (FHA) mortgage servicer’s engagement with a borrower in default. 4 Overall, we were supportive of the proposal, specifically that servicers should be able to utilize successful techniques and technologies to engage borrowers facing financial hardship.
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MBA Joint Letter to HUD on Face-to-Face Requirements
The Mortgage Bankers Association (MBA), American Bankers Association (ABA), Housing Policy Council (HPC), and the National Mortgage Servicing Association (NMSA) (the Associations) respectfully submit these comments in response to the Department of Housing and Urban Development’s (HUD) proposal to modernize the rules applicable to a Federal Housing Administration-insured (FHA) mortgage servicer’s engagement with a borrower in default.
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MBA Letter to HUD on FHA Multifamily Loans Fees and Cost
The Mortgage Bankers Association (MBA) agrees and believes in fairness and transparency in fees charged to consumers. We also believe that these same burdens are placed on renters today by unnecessarily high fees charged by HUD to developers and providers of housing. These costs result in fewer units being developed and higher rents for tenants. Not only are the costs of HUD loans more than the private market and those charged by Fannie Mae and Freddie Mac (the GSEs), but together, these costs are far higher than are needed to cover the risk to the American taxpayer.
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MBA Coalition Letter on FHFA Suspended Counterparty Program NPR
The American Bankers Association (ABA), Independent Community Bankers of America (ICBA), and Mortgage Bankers Association (MBA) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) proposal to amend the existing Suspended Counterparty Program (SCP). FHFA proposes to expand the categories of “covered misconduct” under which a counterparty (e.g., seller/servicer, vendor) suspension could be based. The new categories include sanctions arising from forms of civil misconduct in connection with, for example, the management or ownership of real property. Additionally, FHFA would be able to issue an immediate suspension order when the misconduct has resulted in debarment, suspension, or limited denial of participation imposed by a federal agency.
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MBA Comment on Proposed Interagency Guidance on Reconsiderations of Value (ROV)
The Mortgage Bankers Association (MBA) thanks the Board of Governors of the Federal Reserve System (the Board), the Consumer Financial Protection Bureau (CFPB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) (together, “the Agencies”) for their consideration of industry feedback on the proposed guidance regarding lender policies and procedures for reconsiderations of value (ROVs).
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MBA Coalition Letter on FHFA Suspended Counterparty Program NPR (State MBAs)
The undersigned associations are writing to express serious concerns with the Federal Housing Finance Agency's (FHFA) proposal to amend the existing Suspended Counterparty Program (SCP) regulations. While we recognize the importance of rules that ensure the safety and soundness of the GSEs, this proposal features no rationale for its adoption despite the possibly draconian consequences that could fall on those caught up in an expanded SCP.