MBA Advocacy Update

Steve O'Connor; Bill Killmer

June 04, 2018

Congress was in recess last week. This week, the House Financial Services Committee will hold a hearing on improving transparency and accountability at the Bureau of Consumer Financial Protection.

Looking ahead, MBA is focused on this month's anticipated Senate Appropriations Committee markups of the respective Fiscal Year 2019 Transportation and HUD and Financial Services and General Government subcommittee proposals.

Ginnie Mae Addresses New Loan Seasoning Requirements for VA Refinances
On May 30, Ginnie Mae issued an All Participants Memorandum ( that addresses new loan seasoning requirements for VA refinances, based on the financial regulatory relief legislation (S. 2155) that passed last month.

It requires an extension:
A) 210 days after the first payment on the initial loan; or
B) the date on which 6 full monthly payments have been made on the initial loan.

This will adversely affect lenders who have certified new pools for June issuance that contain VA refis that are not compliant, even if the note date of the VA refi is prior to the date of the APM or enactment of the law. Ginnie is currently reaching out to individual lenders who may now have defective loans in pools that were certified for June issuance. Please note that Ginnie securities issued before June will not be affected.

MBA is in constant communication with Ginnie Mae regarding the matter and will continue to work with them and individual lenders to deal with issues as they arise.

For more information, please contact Dan Fichtler at (202) 557-2780; or Julienne Joseph at (202) 557-2782

MBA Releases Updated UDAAP Enforcement Actions Matrix
MBA has updated its UDAAP Matrix (unfair, deceptive, or abusive acts or practices) with a list of instances where UDAAPs have been addressed by the Bureau of Consumer Financial Protection in its Supervisory Highlights.

The matrix is organized by category, sub-category (if applicable) and UDAAP. The Supervisory Highlight issue, section, and page number is also listed for reference. It should be noted, however, that in addition to the statutory definition provided by Dodd‐Frank, the BCFP has yet to formally address by regulation or otherwise what constitutes an abusive act or practice. MBA's UDAAP Matrix is an exclusive MBA member benefit and is available for download at Enforcement Actions Matrix.pdf.

For more information please contact Justin Wiseman at (202) 557-2854; or Blake Chavis at (202) 557-2930

MBA Submits Comment Letter on BCFP RFI on External Engagements
Last week, MBA sent a letter to the Bureau of Consumer Financial Protection, calling on the Bureau to create an advisory council focused on the mortgage industry and urged them to ensure that it receives input from diverse and varied viewpoints, including those of independent mortgage banks.

The letter--the latest in a series of MBA responses to more than a dozen BCFP Requests for Information--addresses ways in which the Bureau could improve its external engagement process. Key to this, MBA said, is establishment of a Housing Finance Advisory Council.

For more information please contact Justin Wiseman at (202) 557-2854; or Blake Chavis at (202) 557-2930

MBA Education Webinar on TRID 2.0 Implementation June 26
Join MBA Education and the Compliance Essentials program on June 26 for a timely discussion on the latest news and guidance surrounding the Know Before You Owe Rule (TRID). I

n this discussion, we will be looking toward October implementation and will address questions from you regarding what you are still struggling with and what issues you are currently encountering. Leading legal and industry minds will be prepared to respond to your questions and share insights on the policies and procedures you need to be implementing in order to remain in compliance and run a productive business.

To register for the webinar, click

For more information, please contact Lisa Volb at (202) 557-2919

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