Resources
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Nonprofit Membership Application
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Commercial/Multifamily Membership Application
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MBA Letter to FHFA on Tenant Protections RFI
The Mortgage Bankers Association (MBA) appreciates the opportunity to provide comments and recommendations on the impact of requiring additional enhancements for tenants at Enterprise-backed multifamily properties. The MBA thanks FHFA for its commitment to working with the industry on this issue and remaining open to receiving feedback from a variety of stakeholders.
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MBA Joint Letter to CFPB on Residential Property Assessed Clean Energy Financing (Regulation Z)
On behalf of the clients, communities, and industries we represent, we write in strong support of the Bureau’s proposed rule applying Regulation Z to Residential Property Assessed Clean Energy (PACE) loans. In the proposed rule, the Bureau correctly recognizes that PACE financing fundamentally acts as mortgage credit, yet is provided by underregulated or unsupervised entities that often exploit the lien priority granted to tax assessments. As a result, residential PACE financing should be subject to the same regulations that apply to first-lien mortgages.
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MBA Joint Letter to VA on VASP
The Mortgage Bankers Associations (MBA) and the Housing Policy Council request that the Department of Veterans Affairs (VA) provide a public process for review and comment on VA’s new foreclosure prevention solution, the Veterans Assistance Servicing Purchase (VASP) program. Specifically, the VA should allow a 30-day comment period before finalization of any new policy to be effective in the VA Servicer Handbook with a subsequent appropriate implementation period.
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MBA Comment Letter to HFSC on ESG/CRA Sec. 1071 Markup
Mortgage Bankers Association (MBA) writes to share our views on the planned Financial Services Committee markup of several real estate finance-related bills, scheduled for July 27, 2023.
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President and CEO Bob Broeksmit Letter to Banking Agency Leadership on MBA’s Opposition to Interagency Proposed Bank Capital Rule
The Mortgage Bankers Association (MBA) strongly urges you to vote against the proposed interagency Notice of Proposed Rulemaking implementing the Basel III “endgame” rule, which is set for consideration on July 27. The rule is expected to impose a 15 to 20 percent increase in capital requirements for larger institutions.
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MBA Joint Letter to Banking Agencies on Proposed Capital Rules
We are writing to express our deep concern about reports that you are considering significantly increasing capital standards on some mortgages with down payments of less than 20%. Such a significant increase in capital standards will lead to reduced credit availability for all types of lending and undermine economic growth.
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MBA Joint Letter to ULC on Illegal Discriminatory Covenants
A joint letter to thank the Uniform Law Commission (ULC) and specifically the Unlawful Restrictions in Land Records Committee for their work in drafting legislation to address illegal discriminatory covenants placed in property records prior to the US Supreme Court case Shelley v Kraemer and the enactment of fair housing laws. To endorse the draft Act and look forward to its adoption by the ULC, introduction in state legislatures, and ultimate passage around the country.
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MBA Letter to Financial Stability Oversight Council (FSOC) on Proposed SIFI Designation Guidance
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 supports FSOC’s goal to ensure healthy and stable financial markets, however as further outlined below, MBA recommends FSOC incorporate several improvements to the proposal and the framework when considering designation of a non-bank financial firm as a SIFI.
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MBA Letter to S&P Global Ratings on Insurer Risk-Based Capital Adequacy
The Mortgage Bankers Association respectfully submits our comments below in response to S&P Global’s request for comment on its proposed revisions to Insurer Risk-Based Capital (RBC) Adequacy – Methodology and Assumptions (the “Proposal”).
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MBA Letter to Conference of State Bank Supervisors on NMLS Mortgage Call Report Revisions
Mortgage Bankers Association (MBA) wanted to take a moment to relate some thoughts that have been expressed to us by representatives of our member companies to you and your team at CSBS. Some of these topics relate specifically to the MCR and others relate to the potential for alignment or divergence with the reporting requirements of the Mortgage Bankers Financial Reporting Form (MBFRF).
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MBA Joint Letter to NAIC on Practices & Procedures (P&P) Manual Amendment
The undersigned (ACLI, PPIA, NASVA, SFA, MBA, and CREFC) appreciate the opportunity to comment on the exposure referred to above that was released for comment by the VOSTF on May 15, 2023. We generally like to provide constructive comments on VOSTF exposures and provide support wherever possible. Regarding this exposure, the undersigned have concerns with the proposal and believe additional transparency is warranted. We also recommend changes that are necessary to avoid significant unintended consequences.
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MBA Letter to FTC on Data Privacy and Protection ANPR
The Mortgage Bankers Association (MBA) appreciates the opportunity to comment on the Federal Trade Commission’s (FTC) Advanced Notice of Proposed Rulemaking (ANPR) on the issues of data privacy and protection.
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MBA Comment Letter to CSBS on NMLS Mortgage Call Report
Mortgage Bankers Association (MBA) continues to appreciate the collaborative relationship between our organizations, and among our respective members. They appreciate the challenges CSBS and the state regulator community face in bringing greater consistency to various state requirements – it is not an easy task. As evidenced by the current regulator industry collaboration on the MISMO Lender Examination File Format Working Group, there is much promise that can come from this effort.
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MBA Comment Letter on Real Estate Amendments in H.R. 2670 (NDAA FY 2024)
MBA Comment Letter on Real Estate Amendments to FY2024 NDAA
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MBA Joint Letter on House 199A Permanence Bill
The undersigned business groups strongly support the introduction of your Main Street Tax Certainty Act of 2023, legislation to make permanent the 20-percent deduction for small- and individually-owned businesses (Section 199A).
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MBA Joint Comment Letter on CFPB’s Statement of Policy Regarding Prohibition on Abusive Acts or Practices
The Bank Policy Institute, American Financial Services Association, Consumer Bankers Association, Credit Union National Association, Mortgage Bankers Association, and the U.S. Chamber of Commerce are providing these comments in response to the Consumer Financial Protection Bureau’s Statement of Policy Regarding the Prohibition on Abusive Acts or Practices (Docket No. CFPB–2023–0018). The Bureau asserts that the Statement became effective on April 12, 2023, but that the Bureau is nevertheless soliciting comments on it.
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Joint Trade Letter to FHA’s Proposal to Assist Borrowers in High-Interest Rate Environment
The Mortgage Bankers Association (MBA), American Bankers Association (ABA), and the National Mortgage Servicing Association (NMSA) (the Associations) comment on the Federal Housing Administration’s (FHA) Draft Mortgagee Letter (Draft ML), Payment Supplement Partial Claim (PSPC). The Associations agree with the need for a loss mitigation solution that provides payment relief to seriously delinquent FHA borrowers in a high-rate environment, while protecting Ginnie Mae issuers from losses. However, as drafted, the complex and resource intensive PSPC would significantly increase the operational, compliance, liquidity, and reputational risk for mortgage servicers, while introducing potential harm to borrowers.
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MBA Comment Letter to FHFA on Fair Lending, Fair Housing, and Equitable Housing Finance Plans
The Mortgage Bankers Association (MBA) respectfully submits these comments in response to the Federal Housing Finance Agency’s (FHFA) proposed rule regarding its fair lending oversight of the regulated entities, and the Equitable Housing Finance Plans (EHFP) of Fannie Mae and Freddie Mac (the Enterprises).