MBA CREF Policy Update Sept. 22, 2022

Bill Killmer; Mike Flood

Last Thursday, SEC Chair Gary Gensler defended his agency’s position on cryptocurrencies and its push to include climate risks into public company disclosures during a hearing before the Senate Banking Committee. Also last week, the OCC announced the appointment of Dr. Yue (Nina) Chen as Chief Climate Risk Officer and MBA released second-quarter 2022 data on commercial and multifamily mortgage delinquencies.

MBA recently released a new white paper titled, A Framework for Considering Office Demand in a Post-Pandemic World, which details the relative benefits and costs of remote and in-person work to employees and employers and analyzes the outlook for the office sector and potential impacts to commercial mortgage loan volume and property values.

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. 

SEC’s Gensler Testifies In Senate; Senators Press On Climate Disclosure Rule

Last Thursday, U.S. Securities and Exchange Commission Chairman Gary Gensler defended his agency’s position on cryptocurrencies and its push to include climate risks within public company disclosures during a hearing before the Senate Banking Committee. Both Republicans and Democrats questioned the burdensome effect the SEC’s climate-risk disclosure rule will have on public companies. Chairman Gensler stated that most of the comments received so far have been supportive of investors using climate-disclosure information and that the rulemaking fits into the SEC’s history of how disclosures are made. A summary of the hearing can be found here.

  • Why it matters: The SEC climate-risk rule would require reporting of direct greenhouse gas emissions and indirect emissions from purchased electricity and other forms of energy.
  • What’s next: MBA submitted a comment letter in June responding to the SEC’s climate disclosure rule. The SEC will consider a tremendously large number of comments before issuing a final rule, with an aspirational target of issuing a final rule with an effective date in December 2022.

For more information, please contact Ethan Saxon at (202) 557-2913 or Tallman Johnson at (202) 557-2866.

OCC Appoints New Climate Risk Officer  

Last Monday, the Office of the Comptroller of the Currency announced the appointment of Dr. Yue (Nina) Chen as Chief Climate Risk Officer.

  • Why it matters: According to the announcement, “Dr. Chen will lead the agency’s climate risk efforts related to supervision, policy, and external engagement. She will oversee the activities of the OCC’s Office of Climate Risk and report directly to the Acting Comptroller of the Currency. Under Dr. Chen’s leadership, the OCC will continue to focus on the development and implementation of climate risk management frameworks for the federal banking system.”
  • What’s next: OCC Comptroller Michael Hsu has urged the financial services industry to address and manage risks associated with climate change. MBA is following the banking agencies’ ongoing efforts to address climate related issues.

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

Basel Oversight Committee Reaffirms Basel III Implementation

Last week the Group of Central Bank Governors and Heads of Supervision (GHOS), the oversight body of the Basel Committee on Banking Supervision, met to provide direction on key areas of work by the Committee.

  • Why it matters: Finalized in 2017, the Committee reaffirmed its implementation dates for Basel III.
  • What’s next: According to the Committee, more than two-thirds of jurisdictions plan to implement all or a majority of Basel III standards by 2023 or 2024, with the remaining planned for implementation in 2025.

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

Commercial and Multifamily Mortgage Delinquency Rates Remain Low in Second-Quarter 2022

Commercial and multifamily mortgage delinquencies declined in the second quarter of 2022, according to the Mortgage Bankers Association’s latest Commercial/Multifamily Delinquency Report, released last Tuesday.

  • MBA’s Vice President of Commercial Real Estate Research Jamie Woodwell said, “Delinquency rates for commercial and multifamily mortgages fell again during the second quarter of 2022. Many capital sources are seeing delinquency rates at or approaching pre-pandemic levels, which were some of the lowest delinquency rates on record. MBA survey data have shown significant differences by property type as the COVID-19 pandemic’s effects have morphed. These property-type differences, particularly across changing economic conditions, will continue to be a key factor in commercial and multifamily loan performance.”
  • To view the report, click here.

For more information, please contact Jamie Woodwell at (202) 557-2936.

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:

  • State of Non-QM Lending & What You Need to Know Now – September 27
  • Empowering Mortgage Servicers with Proactive KPIs – September 29
  • Managing Liquidity and Operational Efficiency in a Fiercely Competitive Market – October 4
  • Marijuana and Real Estate in 2022: What Every CRE Professional Should Know – October 19

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.