MBA CREF Policy Update Oct. 20, 2022
Bill Killmer bkillmer@mba.org; Mike Flood mflood@mba.org
MBA submitted a comment letter to FHFA on its Notice of Proposed Rulemaking for the 2023-2024 multifamily enterprise housing goals. On Thursday, MBA signed a joint trades letter to support the Revitalizing Downtowns Act (H.R. 4759/S. 2511), which would provide tax credits and benefits for the conversion of underutilized or vacant office buildings. And on Friday, MBA submitted a comment letter in response to FHFA’s Request for Input on the roles, related processes, risks and opportunities of technology in housing finance.
MBA is now accepting applications for its Commercial/Multifamily Diversity, Equity, & Inclusion Leadership Awards. For more information and to apply, click here.
Sign MBA’s Home for All Pledge: Join the 320+ 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.
MBA Submits Comments on FHFA’s 2023-2024 Multifamily Housing Goals Proposal
On Thursday, MBA submitted a comment letter to the Federal Housing Finance Agency (FHFA) on its Notice of Proposed Rulemaking for the 2023-2024 multifamily enterprise housing goals. The rule proposes a new methodology for measuring the Enterprises’ multifamily housing goals and is applicable to the years 2023 and 2024. MBA is supportive of the new approach and encouraged FHFA to work toward more simplification of the various affordable and mission-related goals.
- Why it matters: Rather than establishing the multifamily housing goals based on a fixed number of units, the proposed rule would use the percentage of each Enterprise’s annual multifamily loan acquisitions (in units) that are affordable to each income category. The proposed benchmark levels for 2023-2024 are 61% of annual loan acquisitions (in units) for the low-income goal (80 Area Median Income [AMI]), 12% for the very low-income subgoal (50 AMI), and 2% for the small multifamily low-income subgoal (80 AMI). Relying, in part, on the data and forecasts of MBA, FHFA took into consideration various economic factors when determining the proposed housing goals. FHFA is not proposing a change to the criteria that determine which units qualify for housing goal credit.
- What’s next: MBA will monitor progress on a final rule and will communicate all relevant information to members.
For more information, please contact Stephanie Milner at (202) 557-2747.
MBA Signs Joint Trades Letter Supporting Property Revitalization Tax Incentive
On Thursday, MBA signed a joint trades letter to support the Revitalizing Downtowns Act (H.R. 4759/S. 2511), which would provide tax credits and benefits for the conversion of underutilized or vacant office buildings.
- Why it matters: Introduced by Sen. Debbie Stabenow (D-MI) and Rep. Jimmy Gomez (D-CA), the bill is intended to help cities convert unused office space for other purposes, including the creation of affordable housing units, in an effort to revitalize urban areas (and keep downtown areas prosperous). A project may qualify for the credit if the conversion provides at least 20% of its utilization for affordable housing (i.e., housing dedicated to households whose income does not exceed 80% of the AMI).
- What’s next: Though consideration of the bill is unlikely prior to year’s end, MBA and its coalition partners will continue to work with the bill’s authors and push for additional enhancements to the proposal that would help reduce housing costs within, and drive additional investment toward, eligible projects.
For more information, please contactAlden Knowlton at (202) 557-2741, Ethan Saxon at (202) 557-2913, or Grant Carlson at (202) 557-2765.
MBA Signs Joint Trades Letter Supporting Property Revitalization Tax Incentive
On Thursday, MBA signed a joint trades letter to support the Revitalizing Downtowns Act (H.R. 4759/S. 2511), which would provide tax credits and benefits for the conversion of underutilized or vacant office buildings.
- Why it matters: Introduced by Sen. Debbie Stabenow (D-MI) and Rep. Jimmy Gomez (D-CA), the bill is intended to help cities convert unused office space for other purposes, including the creation of affordable housing units, in an effort to revitalize urban areas (and keep downtown areas prosperous). A project may qualify for the credit if the conversion provides at least 20% of its utilization for affordable housing (i.e., housing dedicated to households whose income does not exceed 80% of the AMI).
- What’s next: Though consideration of the bill is unlikely prior to year’s end, MBA and its coalition partners will continue to work with the bill’s authors and push for additional enhancements to the proposal that would help reduce housing costs within, and drive additional investment toward, eligible projects.
For more information, please contactAlden Knowlton at (202) 557-2741, Ethan Saxon at (202) 557-2913, or Grant Carlson at (202) 557-2765.
Financial Stability Board Sends Letter to the G-20 Calling for Climate Change Disclosures
On Tuesday, a Financial Stability Board (FSB) letter sent to the G-20 included a section calling for enhanced and more uniform climate change disclosures by public companies. The letter provides support for the Securities and Exchange Commission’s (SEC) proposed rule on the enhancement and standardization of climate-related disclosures.
- Why it matters: The letter notes “work on other areas of the FSB Roadmap for Addressing Climate-Related Financial Risks is also progressing. We have submitted to you the final version of the FSB’s recommendations on supervisory and regulatory approaches to climate-related risks, following a public consultation. Moreover, the FSB will publish its joint work with the Network of Central Banks and Supervisors for Greening the Financial System (NGFS) on climate scenarios in November.”
- What’s next: The SEC is expected to issue a final rule early next year.
For more information, please contact Grant Carlson at (202)-557-2765.
G7 Finance Ministers and Central Bank Governors Issue Joint Climate Pledge
On Wednesday, G7 Finance Ministers and Central Bank Governors issued a joint statement committing “to ambitious climate action and to promoting an orderly and just global transition toward net zero greenhouse gas emissions.”
- Why it matters: The group pledged to make substantial progress toward reaching the Paris Accord’s goals to combat climate change and to contribute $100 billion annually through 2025 to address climate needs in developing countries. In addition, the group pledged to “actively support work on climate and disaster risk finance and insurance and we will work toward progress regarding Climate-Resilient Debt Clauses and the Global Shield against Climate Risks.”
- What’s next: Next month, 90 heads of state will meet in Egypt at the Conference of Parties (COP) climate conference to review communications and actions members have made to reduce emissions.
For more information, please contact Grant Carlson at (202) 557-2765.
State Trackers
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:
- Modern Day Redlining in Focus: Takeaways from Trident Mortgage and Beyond – October 20
- Climate Risk in CREF – What we know and are learning – November 1
- Augmenting Talent with Technology – November 8
- TRID Housekeeping & Latest Information – November 15
- Inflation, Interest Rate, Cap Rates & Values: What Do We Really Know? – November 30
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.
