Resources
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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.
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MBA President and CEO Bob Broeksmit, CMB Statement on Implementing Basel III
The Mortgage Bankers Association (MBA) appreciates the opportunity to comment on the issues raised by the Financial Institutions and Monetary Policy Subcommittee’s September 14, 2023, legislative hearing entitled, “Implementing Basel III: What’s the Fed’s Endgame?” MBA strongly opposes key elements of the proposal, which, absent significant revisions, our industry fears will increase borrowing costs and reduce credit availability.
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MBA Joint Letter on Extending the NFIP
The undersigned organizations urge Congress to act quickly to extend the National Flood Insurance Program (NFIP) before its September 30th expiration. Extending the NFIP would ensure this vital program does not lapse in the middle of hurricane season or create additional challenges for residential and commercial property owners, buyers, managers, renters, and tenants.
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MBA Statement for the Record for Senate Banking Committee Hearing on Flood Insurance
Mortgage Bankers Association (MBA) provides perspective regarding challenges within the property insurance market and their impact on consumers prior to the committee’s hearing on the issue this week. Property insurance is the first line of financial defense for homeowners, commercial owner/operators, and lenders in the event a property is damaged. The availability and affordability of property insurance impacts these groups directly, but also has downstream impacts on the broader real estate market, including lending, construction, and the availability of affordable housing – for both renters and homeowners.
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MBA Comment Letter to Financial Accounting Standards Board on its Proposed Accounting Standards Update
MBA represents over 2,200 member companies, including bank and non-bank lenders, servicers, and sub-servicers in both the residential and commercial markets. MBA members originate and sell mortgage loans as part of their business and play a vitally important role in the mortgage secondary markets. MBA supports FASB’s goal of simplifying the accounting for purchased financial assets by eliminating one of the two methods for accounting for purchased financial assets, thereby reducing complexities and comparability issues that have been identified in the current rule. MBA recommends that FASB apply this simplified method of accounting to mortgage loans purchased by an entity, regardless of when the loans were originated.
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MBA Comment Letter to HUD on Notice of Proposed Information Collection
The Mortgage Bankers Association (MBA) and its members appreciate the opportunity to offer comments on the Office of Policy Development and Research’s Notice of Proposed Information Collection concerning the Informed Consumer Choice Disclosure and Application for FHA Insured Mortgages. MBA and its members value the Department of Housing and Urban Development’s (HUD) continued effort to work with the industry to identify opportunities to improve efficiency and lower cost for consumers.
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MBA Joint Comment Letter to VA on Public Comment Process for Foreclosure Prevention Solution for Veteran Borrowers
On behalf of the clients, communities, companies, and borrowers we serve, MBA urge the VA to post a draft policy document regarding Veterans Assistance Servicing Purchase (VASP) program by September 21, 2023. The current state of loss mitigation options requires urgent action, and while we appreciate the dialogue VA has had with stakeholders, it is time for the agency to start a public process for review and comment on VA’s new foreclosure prevention solution.
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Basel III Bank Capital Proposal – MBA Summary
This MBA summary outlines the Banking Agencies’ Proposed Changes to Bank Capital Requirements for banks with assets of $100 billion or more.