Resources
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MBA Letter to HUD Requesting Federal Flood Risk Management Standard (FFRMS) Extension
MBA Letter sent a letter, signed by more than 30 MAP lenders and service providers, to HUD asking to push back the effective date of the Federal Flood Risk Management Standard (FFRMS). The rule is set to go into effect for FHA Multifamily applications and pre-applications submitted after September 1, 2024.
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MBA Comment Letter on FHA Appendix 8.0 FHA Defect Taxonomy for Servicing Loan Reviews
MBA comments on the Federal Housing Administration’s (FHA) proposed Appendix 8.0 FHA Defect Taxonomy for Servicing Loan Reviews. A Defect Taxonomy addresses loan-level defects or noncompliance with FHA’s Single-Family Housing policies. FHA’s framework must consistently categorize defects and apply the appropriate remedy to become a predictable and effective tool.
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MBA, HPC Letter to VA on VASP Implementation Extension Request
Mortgage Bankers Association (MBA) and Housing Policy Council (HPC) request that the Department of Veterans Affairs (VA) extend the mandatory compliance date for the Veterans Affairs Servicing Purchase program (VASP) to December 31, 2024. Given the complexity of the program and the ongoing policy changes and clarifications published as recently as last week, we believe additional time is necessary for mortgage servicers to successfully update their processes to implement VASP.
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MBA Letter to HUD to Roll Back the Debt Service Coverage Ratio
The undersigned organizations represent FHA multifamily housing providers, lenders, and developers. HUD’s multifamily production levels have significantly declined in recent years. Between FY 2022 and FY 2023, volume dropped by 58%. Based on production data through May 2024, MAP loan volume is expected to decrease by an additional 29.75%. While interest rates are certainly a factor, the fees and requirements of FHA multifamily insured loans also play a role.
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MBA Letter to CFPB on Comment Period Extension for Delaying Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders
MBA Letter to CFPB on Comment Period Extension for Delaying Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders
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MBA Joint Trade Letter to HUD on Section 232 Properties
The Healthcare Mortgagee Advisory Council (HMAC), its Section 232 lender members, the MBA and trade groups representing the nursing home and senior living industry, would like to acknowledge the highly valued partnership we have had with HUD since the creation of the 232 program. It is because of this history of partnership that we want to bring to your attention an issue causing great concern for Section 232 lenders and for the industry partners jointly signing this letter.
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MBA Joint Letter on California AI Bill
MBA Joint Letter on California AI Bill
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MBA Comment Letter to CFPB on Mortgage Closing Costs RFI
The Mortgage Bankers Association (MBA) appreciates the opportunity to respond to the Consumer Financial Protection Bureau’s (CFPB or Bureau) request for information (RFI) regarding fees imposed in residential mortgage transactions. Promoting affordable and sustainable homeownership and removing barriers to homeownership is a shared goal of MBA and the CFPB. However, the Bureau’s focus on mortgage closing costs is misguided and inaccurately characterizes certain disclosed, required and necessary mortgage-related fees as “junk fees” in its press releases, blogs, circulars, advisory opinions, and public speeches. These statements suggest that the CFPB may have already arrived at predetermined conclusions about the questions in this RFI and the validity of these charges.
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MBA Joint Trades Letter on the CFPB’s RFI on Mortgage Closing Costs
The Associations support the Bureau’s interest in understanding the affordability challenges facing the housing market. It is regrettable that the CFPB is inaccurately characterizing certain fully disclosed, statutorily required and necessary mortgage-related fees as “junk fees” through blogs, circulars, advisory opinions, and public speeches. It is damaging for consumers and industry stakeholders alike to have the principal consumer financial protection regulator mischaracterize legitimate and fully disclosed fees associated with products and services that are of crucial financial utility and serve critical risk management purposes.
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MBA Joint Letter to Ginnie Mae on Proposed HMBS 2.0 Term Sheet
National Reverse Mortgage Lenders Association and the Mortgage Bankers Association (the “Associations”) write to commend Ginnie Mae’s efforts to boost liquidity for HECM issuers and emphasizes key recommendations to streamline processes, reduce costs, and ensure operation efficiency.
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MBA Joint Letter on H.R. 8127, The Heirs Estate Inheritance Resolution and Succession (HEIRS) Act of 2024.
The undersigned organizations, write to express our strong support for H.R. 8127, The Heirs Estate Inheritance Resolution and Succession (HEIRS) Act of 2024. This bipartisan legislation will provide relief to the countless families across the country that are negatively impacted by heirs’ property.
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MBA Comment Letter on Proposed 2025 NMLS Fee Changes
The Mortgage Bankers Association (MBA) appreciates the opportunity to provide comments to the Conference of State Bank Supervisors (CSBS) and State Regulatory Registry, LLC (SRR) in response to the proposed 2025 National Multistate Licensing System (NMLS) Fee Changes.
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MBA Joint Trade Letter Opposing President Joe Biden's Rent Control Proposal
The undersigned national real estate associations write to share our strong opposition to your recent proposal to cap rents nationwide. Rent control policies have proven time and again to increase rents, reduce the capital needed to boost the supply of housing, and ultimately hurt renters today and in the future.
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MBA Joint Trades Letter on the Revitalizing Downtowns and Main Streets Act
The undersigned organizations write in strong support of the Revitalizing Downtowns and Main Streets Act that Representatives Mike Carey and Jimmy Gomez are preparing to introduce. We encourage you to cosponsor and help advance this bipartisan measure that aims to modernize U.S. real estate, create new and affordable housing, and strengthen local communities through a market-based tax incentive for converting older commercial properties to residential use.
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MBA Letter to Treasury and HUD on its Concerns Regarding the Federal Financing Bank (FFB) Risk-Sharing Program
MBA writes to express our concern about the Biden administration’s continued focus on the Federal Financing Bank (FFB) Risk-Sharing Program. The FFB program creates direct and unfair competition with private sector lenders that participate in the Department of Housing and Urban Development’s (HUD) multifamily accelerated processing (MAP) program and may discourage their participation in the market in the future. The Administration should instead focus its efforts to increase supply on changes to the FHA MAP program and allow MAP lenders to access the FFB.
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MBA Joint Trades Letter on Committee Markup of the American Privacy Rights Act
MBA express concerns about the ambiguity of the Gramm-Leach Bliley Act (GLBA) exception provided in the American Privacy Rights Act (APRA) Discussion Draft and advocate for clear language that provide an exception for entities subject to the GLBA.
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MBA Comment Letter on ML for Significant Cybersecurity Incident Reporting Requirements
The Mortgage Bankers Association provides feedback in response to the recent Mortgagee Letter (ML) concerning Significant Cybersecurity Incident reporting requirements. Given the evolving landscape of cybersecurity threats, it is crucial to establish clear, consistent, and practical policies to navigate potential cyberattacks effectively. By doing so, lenders can better safeguard their systems while protecting customers, employees, vendors, counterparties, and agency partners.
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MBA Letter to VA Subcommittee on H.R. 8647, the VA Home Loan Reform Act
Mortgage Bankers Association writes to express the real estate finance industry’s views on the Amendment in the Nature of a Substitute (ANS) to H.R. 8647, the VA Home Loan Reform Act scheduled for markup in the Committee on Veterans’ Affairs’ Economic Opportunity Subcommittee on Thursday, June 27. The bill, as amended, takes an important first step towards providing the Department of Veterans Affairs (VA) and affected homeowners with a solution to resolve delinquencies that other borrowers with government-backed loans already possess. Veterans rightly deserve the same protection and assistance as other homeowners.
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MBA Joint Trade Letter on FY 2025 Ginnie Mae Appropriations
As Congress commences the process of crafting the Fiscal Year (FY) 2025 Transportation and Housing and Urban Development (“T-HUD”) Appropriations bill, we write to express our strong support for full funding of the FY 2025 budget request level of $67 million for salaries and expenses of the Government National Mortgage Association (Ginnie Mae)
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MBA Letter to HUD on NSPIRE Program
MBA writes to the Department of Housing and Urban Development (HUD) to provide written assurance that servicers will not be held accountable for compliance with the new National Standards for the Physical Inspection of Real Estate (NSPIRE) system until it is fully accessible and usable to each participant.