CREF Policy Update April 28, 2022

Commercial and multifamily developments and activities from MBA relevant to your business and our industry.

Last week HUD published fiscal year 2022 income limits for its assisted programs as well as the limits for determining eligibility for low-income housing tax credits and tax-exempt bonds. Last Wednesday, MISMO® announced it is seeking public comment on a standardized questionnaire that borrowers would be asked to answer when applying for a commercial mortgage loan. Please see an article about the questionnaire elsewhere in this issue.

Sign MBA’s Home for All Pledge: Join the 200+ MBA member companies that have signed MBA’s Home for All Pledge, representing a commitment to promoting affordable rental housing; minority homeownership; and company diversity, equity, and inclusion. One senior executive (e.g., CEO, COO, President, Head of Lending, SVP) is encouraged to sign this online form on behalf of your organization. 

View Any Session You Missed from MBA CREF22: Were you one of the over 2,400 registrants that attended MBA’s Commercial/Multifamily Finance Convention & Expo? If you weren’t able to attend every session, they are available to you online for the next month. Simply access the program videos by clicking here. 

1. HUD Publishes FY 2022 Income Limits for HUD-Assisted Programs and Multifamily Tax Subsidy Projects

Last Monday, HUD published fiscal year 2022 income limits for its assisted programs (Section 8, 202 for the elderly, and others), as well as the limits for determining eligibility for low-income housing tax credits (LIHTC) and tax-exempt bonds. Overall, the FY 2022 national median income is $90,000, a 12.5% increase over 2021. For low- or very low-income limits, HUD also made an adjustment to how it calculates a cap on increases year over year, resulting in a maximum increase in limits of 11.89% (vs. 25% of what was expected using the previous methodology that has been in place since 2010). 

• Why it matters: HUD sets income limits annually and they are used to determine eligibility for several HUD-assisted programs, LIHTCs, and tax-exempt bonds. While approximately 99% of areas saw an increase in limits compared to 2021, the change in methodology for calculating the cap on increases year over year on low- and very low-income limits resulted in some areas seeing less of an increase than they otherwise would have with HUD’s previous methodology. This has an impact on the number of renters that may qualify for affordable units and the rent that can be charged for certain properties.
• What’s next: MBA will continue to urge HUD to analyze the impact that new policies, procedures, and regulations have on the ability to increase the supply of affordable housing.  

For more information, contact Stephanie Milner at (202) 557-2747.

2. MISMO Seeks Public Comment on Commercial Green Borrower Questionnaire

Last Wednesday, MISMO®, the real estate finance industry’s standards organization, announced it is seeking public comment on a standardized questionnaire that borrowers would be asked to answer when applying for a commercial mortgage loan.

• Why it matters: MISMO’s Environmental, Social and Governance (ESG) community of practice (CoP) gained input from commercial lending professionals who collaborated to develop and standardize a set of questions that borrowers are asked to answer when applying for a commercial loan. These standardized questions are designed to assist lenders in gathering borrower information when originating, underwriting, or servicing commercial loans in order to increase borrower participation in ESG.
• What’s next: The 60-day comment period runs through June 21, 2022.

For more information, contact Tara Dunion at (202) 557-2849.

3. Acting Comptroller of the Currency Addresses CRA 

Last Tuesday, Acting Comptroller of the Currency Michael Hsu, in a speech entitled “Advancing Fair Access to Quality and Sustainable Credit,” addressed possible regulatory changes to the Community Reinvestment Act.

• Why it matters: Comptroller Hsu remarked, “I expect there will be an interagency CRA Notice of Proposed Rulemaking soon.”
• What’s next: MBA is following regulatory changes to the CRA and will work with members to provide comments.

For more information, contact Grant Carlson at (202)-557-2765.

4. Treasury Secretary Yellen Addresses Coalition of Finance Ministers for Climate Action

On Tuesday, U.S. Treasury Secretary Janet Yellen addressed members of the Intergovernmental Panel on Climate Change (IPPC).

• Why it matters: Secretary Yellen remarked during the panel, “We know that a key path to energy security runs through renewable energy. Our priority – not only in the United States and Europe, but globally – should be on increasing deployment of energy efficiency measures while rapidly scaling up clean energy capacity.”
• What’s next: The U.S. government will launch PREPARE, “the President’s Emergency Plan for Adaptation and Resilience, which outlines a coordinated approach that will put into action the largest U.S. commitment ever made to reduce climate impacts on those most vulnerable to climate change worldwide.”

For more information, contact Grant Carlson at (202)-557-2765.

5. State Trackers

• State eviction moratorium and legislative activity tracker available here.

For more information, contact William Kooper at (202) 557-2737 or Grant Carlson at (202) 557-2765.

6. [WATCH]: mPower Moments: On Success and Being Your Own Champion with Rita Moreno  

In this episode of mPower Moments, mPower Founder Marcia M. Davies had the honor of interviewing the one and only Rita Moreno, winner of all four of the most prestigious awards in show business — an Oscar, a Tony, two Emmys, and a Grammy. Tune into this funny, enlightening, and motivating conversation as Moreno discusses her journey and lessons learned along the way.

• What’s next: To watch more mPower Moments, click here.

For more information, contact Marcia Davies at (202) 557-2707

8. MBA Education Webinars on Critical Industry Issues

MBA Education continues to deliver timely programming that covers the spectrum of challenges, obstacles and solutions pertaining to our industry. Below, please see a list of recent and upcoming webinars, which are complimentary to MBA members:

• CONVERGENCE: Measuring Housing Affordability in America – April 25
• Introduction to Commercial Mortgage-Backed Securities – May 19
• New Fannie Mae and Freddie Mac Condominium and Cooperative Guideline Changes – May 24
• What Trends will Shape the Lending Space in the Second Half of 2022 – June 2
• Serving Loan Applicants with Limited English Proficiency – June 14
• Leveling Up Your Social Media Strategy with Paid Advertising – June 28

MBA members can register for any of the above events and view recent webinar recordings.

For more information, contact David Upbin at (202) 557-2931.