Resources
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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).
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MBA Comment Letter to House Leadership on GSE Pricing
Mortgage Bankers Association writes to express our views regarding provisions within H.R. 3564, the Middle-Class Borrower Protection Act of 2023, which is scheduled to be considered by the full U.S. House of Representatives June 23, 2023. MBA appreciates the opportunity to offer our comments on the self-executing “Manager’s Amendment” to the bill intended to address the Federal Housing Finance Agency’s (FHFA) recent pricing changes for the housing Government Sponsored Enterprises (the GSEs), Fannie Mae and Freddie Mac.
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MBA Joint Letter to FHFA on Credit Score Implementation
On behalf of the American Bankers Association, Center for Responsible Lending, Community Home Lenders of America, Consumer Bankers Association, Credit Union National Association, Housing Policy Council, Independent Community Bankers of America, Leading Builders of America, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Association of Home Builders of the United States, National Association of REALTORS®, National Housing Conference, Reinsurance Association of America, Securities Industry and Financial Markets Association, Structured Finance Association, and U.S. Mortgage Insurers, we appreciate the opportunity to provide stakeholder feedback in response to the Federal Housing Finance Agency’s (“FHFA”) announcement on March 23, 2023 of an implementation plan for the adoption of the FICO 10T and VantageScore 4.0 credit score models, as well as the bi-merge credit reporting policy, by Fannie Mae and Freddie Mac (collectively “the Enterprises”).
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MBA Comment Letter to House Ways and Means Committee on H.R. 3936, H.R. 3937, and H.R. 3938
Mortgage Bankers Association offers the real estate finance industry’s comments on the recently released text of H.R. 3936, H.R. 3937, and H.R. 3938 – Chairman Smith’s combined economic growth and tax package – scheduled for markup in the House Ways and Means Committee today.
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MBA Comment Letter on FHA HECM Mortgage Letter
The Mortgage Bankers Association appreciates the opportunity to comment on the Federal Housing Administration’s (FHA) draft mortgagee letter, Modifications to the Home Equity Conversion Mortgage (HECM) Requirements Related to Secretary Payment of Borrower Disbursements Due to Mortgagee Default. MBA supports FHA’s proposal to revise the agency’s investigation requirements regarding whether a mortgagee can meet their disbursement obligation to HECM borrowers. MBA also applauds efforts by FHA to require a mortgagee who failed to make a distribution obligation to provide information to FHA.
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MBA Joint Letter to FCC on Illegal Text Messages and "Lead Generators"
The American Bankers Association (ABA), ACA International, American Financial Services Association, Bank Policy Institute, Credit Union National Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources, and Student Loan Servicing Alliance (the Associations) appreciate the opportunity to comment on the Further Notice of Proposed Rulemaking (Further Notice) in the above-captioned proceeding.
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MBA Letter to HUD in Response to Floodplain Proposal
The Mortgage Bankers Association (MBA) respectfully submits these comments on HUD’s proposed rule on Floodplain management. HUD’s Proposal is extensive and will impact the construction and substantial improvement of a significant number of residential properties throughout the United States.
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MBA Response Letter to HUD on Floodplain Proposal
The Mortgage Bankers Association (MBA) respectfully submits these comments on HUD’s proposed rule on Floodplain management. HUD’s Proposal is extensive and will impact the construction and substantial improvement of a significant number of residential properties throughout the United States.
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Joint Trades Letter to FHFA on a Uniform ROV Process
On behalf of a collaboration of industry trade associations, consumer advocates, civil rights organizations and the companies, customers, and communities MBA represents, MBA write to encourage the Federal Housing Finance Agency to collaborate with relevant members of the Property Appraisal Valuation Equity (PAVE) Task Force and the GSEs (government-sponsored enterprises/Fannie Mae and Freddie Mac) to develop a uniform reconsideration of value (ROV) process for residential appraisals.
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MBA Comment Letter on HFSC Markup of GSE Pricing Legislation
Mortgage Bankers Association (MBA) writes to share their views on the planned Financial Services Committee markup of an Amendment in the Nature of a Substitute (ANS) to H.R. 3564, the Middle-Class Borrower Protection Act of 2023.
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Coalition Letter to FSOC on the Analytic Framework and Nonbank Guidance Proposals
The undersigned associations are writing in response to the Financial Stability Oversight Council’s (“FSOC” or “the Council”) proposals to revise existing interpretive guidance on nonbank financial company designations (“Nonbank Guidance”) and to adopt an analytic framework the Council would employ to assess potential risks to U.S. financial stability (“Analytic Framework”) (together the “Proposals”). They respectfully request that the Council extend the comment period for each proposal for at least an additional 30 days.