Advocacy and Policy
In This Section
As the leading voice for our industry, we offer a comprehensive view of policy implications in the real estate finance space. We rely on our diverse membership to provide the practical knowledge that makes a real difference on the issues that matter most to the economy, real estate finance industry and its customers.
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Spotlight on What is New and Important Right Now
- MBA's National Advocacy Conference 2020 is open! Attend April 21-22 in Washington, DC and this year you can bring a colleague for FREE on us!
- On November 20, the CFPB released its Fall 2019 Agenda, which for the first time includes a review of the Loan Originator Compensation Rule, after significant advocacy by MBA. The Bureau is considering "whether to permit adjustments to a loan originator's compensation in connection with originating state housing finance authority loans[,]" and "whether to permit creditors to decrease a loan originator's compensation due to the loan originator's error in order to provide clearer rules of the road for regulated entities." This is a very positive first step, and MBA will remain engaged with the Bureau in order to expedite consideration.
- On Friday, the MBA and California Mortgage Bankers Association submitted a letter to the Office of the California Attorney General to comment on its proposed rules to implement the California Consumer Privacy Act (CCPA). The letter makes several requests, including that the California AG provide additional clarity on how to verify a valid consumer request to opt-out or have their information deleted. It also petitions the AG to clarify that only data collected after the effective date of CCPA is subject to enforcement action under the new law.
- Last week, the Federal Reserve, FDIC, and OCC issued a final rule implementing statutory changes to the High Volatility Commercial Real Estate (HVCRE) rule. The rule formalizes the implementation of the 2018 legislation that MBA strongly supported. The final rule is also responsive to MBA's comments on the 2018 proposed HVCRE rule. Specifically, the final rule is responsive to MBA recommendations on the treatment of raw land; treatment of condominium construction; interpretation of "primarily finances," making re-evaluation of loans originated since January 1, 2015, optional instead of mandatory; allowing the use of an "as completed" value for an entire multi-phase project; and rescinding prior HVCRE-related FAQs at the time of implementation. The final rule is effective April 1, 2020, which provides banks with time to transition from reporting under an interagency statement on HVCRE rule implementation.