MBA CREF Policy Update Dec. 1, 2022

Bill Killmer bkillmer@mba.org; Mike Flood mflood@mba.org

MBA Participates in Follow-Up White House Meeting on Tenant Protections 

Last week, Mike Flood, MBA SVP of Commercial/Multifamily, joined a small group of industry and affordable housing leaders for a constructive meeting with key White House and agency staff on affordable rental housing and tenant issues. The meeting was a follow-up to an initial gathering earlier this month on topline issues and best practices for the rental market, including leasing and compliance, housing counseling and education, and affordable housing supply. Attendees at the meeting discussed industry efforts and best practices to enhance tenant protections. 

• Why it matters: Flood’s remarks focused on voluntary commitments members could support, including MBA’s Home for All Pledge, renter counseling, and building renter credit. With a letter from tenant rights groups currently circulating that asks for the White House to impose rent control on GSE loans, Flood again stressed that rent control is not the answer.  
• What’s next: MBA will continue to work with members, the Biden administration, Congress, and industry stakeholders on safe and responsible policies that increase affordable rental housing and homeownership options for all households.

For more information, please contact Bill Killmer at (202) 557-2736 and Mike Flood at (202) 557-2745.

MBA Attends Meeting with Banking Regulators to Discuss Pending CRA Regulatory Changes

Last week, MBA members and staff met with the Federal Deposit Insurance Corporation (FDIC), Federal Reserve Board of Governors (Fed), and Office of the Comptroller of the Currency (OCC) to discuss the Notice of Proposed Rulemaking (NPR) that proposes changes to the Community Reinvestment Act (CRA). MBA members highlighted the concerns with the NPR, including the limits the amount of credit banks can receive for commercial and multifamily lending, the proposed definition of naturally occurring affordable multifamily housing, the treatment of the Low-Income Housing Tax Credit (LIHTC), and green bonds. 

• Why it matters: The nearly 700-page NPR is the first joint agency rulemaking proposing regulatory changes to the CRA since 1995. The NPR proposes significant changes to how banks are evaluated for CRA credit, including expanding the number of activities that qualify for CRA credit while also raising standards for banks to achieve this credit. In addition, the NPR establishes a new affordability definition for naturally occurring affordable multifamily housing and expands CRA credit eligibility to allow banks to receive CRA disaster preparedness, recovery, and climate resiliency.  
• What’s next: MBA will send a follow-up communication to regulators and follow developments as the agencies work towards implementation of a final rule. 

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

State Trackers

• State eviction moratorium and legislative activity tracker available here and here.

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

Upcoming 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 upcoming webinars, which are complimentary to MBA members:

• The Imperative to Control Cost to Originate… A Path Forward – December 6
• Tax Transcripts – Critical Updates to the IRS Process – December 6
• MAA Post-Election Update: November 2022 – December 7
• Ensuring HMDA Data Integrity and Common Reporting Issues – December 14

Ten Things Your Company Must Do in 2023 – January 18

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