MBA Advocacy Update

Steve O'Connor; Bill Killmer  

July 08, 2019

MBA, Coalition Partners Urge Changes to FHA Loan-Level Certifications, Defect Taxonomy
A coalition featuring MBA, the Housing Policy Council, the American Bankers Association and the Bank Policy Institute submitted detailed recommendations to FHA on its proposed revisions to the program's loan-level certifications and Defect Taxonomy (  

These recommendations were developed to limit the overbroad use of the False Claims Act to penalize FHA lenders, often for minor loan defects.  

The coalition's recommendations focused on three areas:  

--Recognition that the underwriting process entails judgment and discretion on the part of the underwriter;

--Exclusion of certifications related to minor defects that would not impact the eligibility of the loan for FHA insurance; and

--Formal incorporation of the Defect Taxonomy to provide greater certainty regarding the remedies for various types of loan defects.  

FHA is expected to consider the public input it has received to date via its "drafting table" approach before publishing a revised version of the loan-level certifications in the Federal Register for an additional round of comments.  

For more information, please contact Justin Wiseman at (202) 557-2854; Fran Mordi at (202) 557-2860; or Dan Fichtler at (202) 557-2780  

House Financial Services Committee Expected to Consider Numerous Bills
MBA anticipates the House Financial Services Committee will hold a significant mark-up--with as many as 20 bills on the docket--beginning Thursday, July 11 and stretching until Tuesday, July 16.  

The focus of the proposals will be grouped into four major policy areas: Consumer Protection, Diversity and Inclusion, Housing and Investor Protection. As is our customary practice, MBA will offer its policy feedback on the bills pertinent to real estate finance in a letter to the committee when the mark-up agenda is formally announced.  

For more information, please contact Dan Grattan at (202) 557-2712; or Ernie Jolly at (202) 557-2736  

MBA Education Servicing and Sub-Servicing Webinar Series July 17
Join MBA Education and industry experts on July 17 for the first in a two-part webinar series that takes a look at the fundamentals and complexities of mortgage servicing and subservicing. Completion of this series will provide registrants with the information necessary to understand servicing and its related components. Anyone who seeks to increase their knowledge of mortgage servicing will benefit from this session that is designed for servicing managers, business owners, executive management, secondary marketing managers and accountants.  

To register for Part One, click   To register for Part Two, click  

For more information, please contact Danielle Jackson at (202) 557-2873

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