Resources
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MBA Joint Letter with CRE Trades on Basel III Endgame
We write today to express concerns that the Basel III Endgame Capital Notice of Proposed Rulemaking (“Proposal”) could have a significant negative impact on the availability of credit for commercial and multifamily real estate.
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MBA Comment Letter on the Banking Agencies’ Basel III Endgame NPR
The Mortgage Bankers Association (MBA) appreciates the opportunity to comment on the notice of proposed rulemaking (NPR) issued by the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC) and the Board of the Governors of the Federal Reserve System (the Board) (jointly, “the Agencies”). The NPR is intended to implement the final components of the Basel III standards to which the U.S. banking system has been gradually transitioning over many years.
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MBA Joint Comment Letter on the Banking Agencies’ Basel III Endgame NPR (Impacts on CRT)
The undersigned housing organizations, are united in our concern that the Basel III Endgame proposed rule, as currently drafted, will cause unintended harm to home loan borrowers by significantly increasing overall required capital and risk weights for mortgage assets held in portfolio by banks. To address this, in addition to other recommendations we may independently and separately make, we ask that your agencies modify your risk-based capital regulations so that it is clear banks can use reinsurance credit risk transfer (CRT) for risk mitigation and receive capital relief for using it.
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MBA Joint Trade Letter on Basel III Recommendations
The undersigned organizations appreciate the opportunity to comment on the notice of proposed rulemaking (NPR) issued by the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC) and the Board of the Governors of the Federal Reserve System (the Board) (jointly, “the Agencies”) to implement the final components of the Basel III standards to which the U.S. banking system has been gradually transitioning over many years.
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MBA Letter to HUD on FHA 203(k) Rehabilitation Mortgage Insurance Program
The Mortgage Bankers Association appreciates the opportunity to provide feedback on the Federal Housing Administration's (FHA) proposed modifications to the FHA 203(k) Rehabilitation Mortgage Insurance Program (203(k) Program). We commend the FHA for its steadfast dedication to addressing the nation's housing affordability challenges, primarily driven by the critically low housing supply.
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MBA Joint Letter to California Privacy Protection Agency on Automated Decision Technology Regulations
The California Mortgage Bankers Association, the Mortgage Bankers Association, the California Bankers Association, and the California Credit Union League, representing the real estate finance industry, appreciates the opportunity to preliminarily comment on the draft regulations noticed on the agenda and discussed at the December 8, 2023, meeting of the California Privacy Protection Agency Board. We look forward to providing more comprehensive comments as the rulemaking process progresses.
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MBA Comment Letter on Rural Housing Service’s Proposed Insurance Regulation
The undersigned organizations representing participants in the affordable and conventional multifamily housing industry, including owners, developers, managers, and lenders are pleased to submit comments on the proposed rule entitled “Insurance Requirements in Multi-Family Housing Direct Loan and Grant Programs” issued by the Rural Housing Service (“RHS”) on October 25, 2023 (the “Proposed Rule”). Members of the undersigned organizations work closely with RHS to ensure that the residents of affordable rural housing live in safe and sanitary housing that is adequately protected by insurance policies that make sense and offer good value to allow the owners to operate the properties.
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MBA Comment Letter to CFPB on Section 1033
MBA Comment Letter to CFPB on Section 1033
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MBA Letter to CFPB on Transparency About Credit Report Pricing Increases
The Mortgage Bankers Association (MBA) is writing to the Consumer Financial Protection Bureau’s (Bureau or CFPB) Office of Research, Monitoring, and Regulations in light of public reports about the recent increased costs of the tri-merge credit reports and other credit reporting products, some of which are required to originate a loan for sale to the GSEs and for government-insured loans.
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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.