Commercial/Multifamily-Specific Coronavirus Resources

MBA's Commercial/Mutlifamily team is working hard to bring our members the most up-to-date information that affects commercial real estate finance during the COVID-19 crisis. We continue to work with government regulators, such as HUD, to try to mitigate risks to the industry and balance public health with this important sector of the economy.

What You Need to Know Now

Life Company COVID-19 RBC and Accounting Relief (4/24/2020)

Bi-Weekly CMF Coronavirus-Related Webinars

Upcoming Webinars

CRE Finance in a World of Uncertainty: Where Are We Headed?
Friday, May 15 |  3:00 PM - 3:45 PM, Eastern | Register
Join MBA and industry experts for a bi-weekly look at the latest issues, concerns, and developments related to commercial real estate finance and the ongoing COVID-19 pandemic. MBA will announce a rotating panel of speakers that represent differing perspectives of the industry and can shed light on what you need to know now.

The New Un-Normal for Multifamily
Wednesday, May 20 |  2:00 PM - 3:00 PM, Eastern | Register
Commercial and multifamily markets were carrying strong momentum into the beginning of 2020. But that was then, this is now. Health, social and economic conditions have deteriorated dramatically, and commercial real estate markets are not immune. Come hear about the new un-normal for multifamily.

The New Un-Normal for Retail Markets
Monday, June 1  |  2:00 PM - 3:00 PM, Eastern | Register
Commercial and multifamily markets were carrying strong momentum into the beginning of 2020. But that was then, this is now. Health, social and economic conditions have deteriorated dramatically, and commercial real estate markets are not immune. Come hear about the new un-normal for Retail markets and how they are affecting property fundamentals through to loan performance.

The New Un-Normal for Retail Markets
Friday, June 5  |  2:00 PM - 3:00 PM, Eastern | Register
Commercial and multifamily markets were carrying strong momentum into the beginning of 2020. But that was then, this is now. Health, social and economic conditions have deteriorated dramatically, and commercial real estate markets are not immune. Come hear about the new un-normal for Lodging markets and how they are affecting property fundamentals through to loan performance.

Webinar Recordings

MBA webinars provide you with the opportunity to learn how our industry is adapting in today's unpredictable environment. Listen in to receive actionable information to help serve your customers.

HUD Multifamily and Healthcare Resources

On April 17, USDA- Multifamily Housing released forbearance guidance on Section 538 loans on Section 4023 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Additionally, the guidance also includes two sample documents to assist in the process: USDA Borrower COVID Forbearance Certification 538 and 538 Lender Sample Forbearance Agreement. RD requests that completed forbearance agreements be sent to Adam Hauptman at adam.hauptman@usda.gov . MBA will continue to work with RD officials to ensure that guidance is provided in a timely manner, and  will continue to provide updates as the situation develops. For more information, please reach out to Sharon Walker at swalker@mba.org

On April 14 HUD released updated Q&A guidance for multifamily loans regarding forbearance, Section 223 (f)s , and move-in and vacancies. Please reach out to Sharon Walker at swalker@mba.org with any questions. 

On April 17, HUD released the following updated Q&A and other guidance for multifamily loans. Of particular interest are remarks given by Brian Montgomery, Acting Deputy Secretary and FHA Commissioner. Lamar Seats, Deputy Assistant Secretary Multifamily and other senior HUD officials also provided updates. Please listen to the latest program updates on SoundCloudFeel free to reach out to Sharon Walker at swalker@mba.org if you have questions.

On March 12, HUD sent a letter on coronavirus to executive directors, tribal leaders, and multifamily property owners.

On March 13, HUD posted Questions and Answers for Office of Multifamily Housing Stakeholders and Questions and Answers for Office of Healthcare Programs External Stakeholders.

On March 16, HUD released a memorandum in collaboration with the Office of General Council (OGC) titled the "Contingency Plans for Closing Multifamily Loans and Similar Commercial Loans during the COVID- 19 Pandemic." This memorandum sets forth protocols and best practices for the continued provision of legal services by HUD Closing Attorneys while working from home or from another remote location. Also included are suggestions that may be shared with outside counsel to facilitate the work being done remotely by OGC attorneys.

FHA Mortgagee Letter on Foreclosure and Eviction Moratorium 
On March 18, HUD released a Mortgagee Letter (ML)  to inform mortgagees of a foreclosure and eviction moratorium for all FHA-insured Single Family mortgages for a period of 60 days. This guidance applies to all FHA Title II Single Family forward and Home Equity Conversion Mortgage (reverse) mortgage programs. HUD invites comment for 30 calendar days from the issue date of the letter. 

On March 24, HUD released another industry update and provided Questions and Answers for Office of Multifamily Housing Stakeholders, which covers concerns related to Emergency Preparedness, Resident Health, Policy and Operations related to Asset Management and Multifamily Production, and Multifamily Housing loan closings among other issues.

MBA Sends Letter to Congressional Leaders Calling for Assistance for Renters and Small Businesses MBA sent a letter to Congressional Leadership calling for action's lawmakers should take to assist renters and small business owners through the economic fallout of COVID-9. The letter calls for emergency rental assistance, title gap reinsurance, a Pandemic Risk Insurance Program, an expansion of small business loans, payroll tax cuts or cancellations, economic impact payments, unemployment compensation tax relief, and revision of rules on Net Operating Loss (NOL) carrybacks.

  • Why it matters: Congress is in the process of developing and finalizing multiple economic packages to address the impact of COVID-9. MBA is working to include measures that help or mitigate negative effects on MBA members, including measures that assist renters and small businesses, thereby helping help borrowers.
  • What's next: Congress is expected to pass legislation as early as this weekend. 

MBA Urges FASB to Treat Banks and Non-Banks Equally for CECL Implementation Under CARES Act

On March 27, MBA sent a letter to the Financial Accounting Standards Board (FASB) requesting they allow all institutions (including life companies, GSE's and mortgage bankers) currently implementing the Current Expected Credit Loss (CECL) standard the option to freeze implementation. The CARES Act, passed by both the House and the Senate, includes a provision giving banks, bank holding companies, and affiliates the option to freeze CECL until the earlier of the end of the termination of the COVID-19 national emergency or December 31, 2020 - but that provision does not apply to other financial institutions. MBA also urged FASB to impose a moratorium on implementation for institutions set to implement in 2023. MBA will continue to advocate for equitable treatment across all financial institutions for any relief efforts.   

On March 30, MBA signed on to a joint-trade letter to the Securities and Exchange Commission (SEC) urging they set and enforce equal implementation time frames for all institutions (including life companies, GSE's and mortgage bankers) currently implementing the Current Expected Credit Loss (CECL) standard. The CARES Act, signed into law on March 27th, includes a provision giving banks, bank holding companies, and affiliates the option to freeze CECL until the earlier of the end of the termination of the COVID-19 national emergency or December 31, 2020 - but that provision does not apply to other financial institutions.

Joint Trade Letter

Asks the Department of Homeland Security to designate construction as an essential service.

Asks that states and local governments  "critical infrastructure" definitions recognize the important role of the financial services sector, as follows:  "The Financial Services Sector includes thousands of depository institutions, providers of investment products, insurance companies, other credit and financing organizations, and the providers of the critical financial utilities and services that support these function." 

Housing Industry Letters

Fannie Mae, Freddie Mac, and FHFA Resources


FHFA Offers COVID-19 Mortgage Forbearance for Multifamily Property Owners

On March 23, FHFA announced Fannie Mae and Freddie Mac (the Enterprises) will offer multi-family property owners mortgage forbearance provided they suspend all evictions for tenants unable to pay rent as a result of COVID-19. These forbearance suspension will remain in place as long as the property owner remains in forbearance. r system. Do not share this message with any third party without the written consent of the sender. 

Related Posts from MBA's CREF Market Intelligence Blog

CRE Finance in a World of Uncertainty - Where are we now
Posted on March 18, 2020 by Jamie Woodwell, Vice President of Commercial/Multifamily Research, MBA
As we've said before, the bad news is that there is a great deal of uncertainty about how the virus will play out in the US, how we will react publicly and privately and what the impact will be on the economy. The good news is that the economy and commercial real estate markets are entering this period from a position of considerable strength. Read More.

Coronavirus, Treasuries and CRE Finance
Posted March 2, 2020 by Jamie Woodwell, Vice President of Commercial/Multifamily Research, MBA
Last week, the week of February 24, 2020, financial markets recognized that the Coronavirus has arrived in the United States. Prior to that, most articles and analyst reports that discussed the economic impact of the virus focused on declines in foreign demand for US goods, or disruptions to international supply chains. With community-spread cases detected in the US, that focus began to turn inward. Read more.