Commercial/Multifamily Policy-Related Updates

Watch this page for the latest information, guidance, and regulatory measures for the Commercial/Multifamily segment of the industry. 

General

Please listen to the latest Multifamily program updates from HUD on SoundCloud. Feel free to reach out to Sharon Walker at swalker@mba.org if you have questions.

  • 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. 
  • 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.
  • 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.             

HUD Multifamily and Healthcare Resources

Please send forbearance agreements to Adam Hauptman at adam.hauptman@usda.gov and please reach out to Sharon Walker at swalker@mba.org with any further questions.

Life Company COVID-19 RBC and Accounting Relief

Accounting Relief

On April 15, 2020, the NAIC Statutory Accounting Principles (E) Working Group (SAPWG) adopted two interpretations related to COVID-19 and accounting relief.

  1.   INT 20-03: Troubled Debt Restructuring Due to COVID-19 - The INT clarifies that a modification of mortgage loan or bank loan terms in response to COVID-19 shall follow the provisions detailed on April 7, 2020, Interagency Statement and section 4013 of the CARES Act.   

  2.   INT 20-04: Mortgage Loan Impairment Assessment Due to COVID-19 - The INT provides limited time exceptions to defer assessments of impairment for bank loans, mortgage loans, and investments that predominantly hold underlying mortgage loans, which are impacted by forbearance or modifications in response to COVID-19. 

RBC Relief 

  1. Guidance for Troubled Debt Restructurings for March 31-June 30 Statutory Financial Statements and Related Interim Risk-Based Capital Filings (where required) - In response to MBA requests, E Committee staff has posted Questions and Answers on March 27, 2020, RBC Guidance, to provide additional clarity. Those Q&As were posted on April 22, 2020.