MBA CREF Policy Update Sept. 8, 2022
Bill Killmer bkillmer@mba.org; Mike Flood mflood@mba.org
Last Wednesday, FHFA announced that it would conduct a comprehensive review of the Federal Home Loan Bank System starting this fall. Also last week, FHA released an amended Administrative Memorandum that extends FHA’s direct to firm submission options for new construction deals through March 31, 2023 and FHA raised approval limits for certain multifamily loans.
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.
FHFA Announces Plans for a Comprehensive Review of the Federal Home Loan Bank System
Last Wednesday, the Federal Housing Finance Agency announced that it would conduct a comprehensive review of the Federal Home Loan Bank system starting this fall. In a press statement applauding the announcement, MBA President and CEO Bob Broeksmit, CMB, said, “We have long supported the responsible expansion of FHLB membership eligibility to better reflect the diverse providers of single-family and multifamily housing finance throughout the country. The Banks’ membership framework has only seen piecemeal updates since its creation, and there’s a need for an FHLB system that better reflects today’s housing finance market — not one from the 1930s.”
- Why it matters: FHFA intends to examine the appropriate role of the FHLB system, including its mission, purpose in the marketplace, and role in prompting affordable, sustainable, equitable, and resilient community investments. In addition, FHFA will examine member eligibility requirements.
- What’s next: FHFA is accepting comments in response to its review through October 21, 2022. In addition, FHFA will hold a listening session on September 29, 2022, from 12:30-4:00 PM ET. Participants can register to attend virtually or in person.
For more information, please contact Stephanie Milner at (202) 557-2747.
FHA Extends Direct to Firm Submissions Through March 31, 2023
Last Wednesday, the Federal Housing Administration released an amended Administrative Memorandum that extends FHA’s direct to firm submission options for new construction deals through March 31, 2023. The only amendment item in the Administrative Memorandum is the extended expiration date.
- Why it matters: On May 26, 2022, MBA sent a letter to FHA requesting this extension, citing delays and significant increases in construction material costs because of rising inflation and supply-chain issues that made finalizing a 221(d)(4) firm application within 120 days a difficult task. FHA will now temporarily permit pre-applications to convert to firm applications while in the queue and will allow new applications to utilize a direct to firm election.
- What’s next: MBA will provide additional information as needed and will continue to advocate for ways to eliminate barriers to financing new multifamily housing.
For more information, please contact Grant Carlson at (202)-557-2765.
FHA Updates Regional and National Loan Committee Limits
FHA last week published updated Regional and National Loan Committee Limits for Section 221 (d)(4), 223 (f), and 223 (a)(7) loans, raising the limits for these loans reviewed by the Regional and National Loan Committee. National Loan Committee for loans greater than or equal to $75 Million ($50 Million if a Cooperative Refinancing) will include a voting member representing the Office of Risk Management (ORM).
- Why it matters: FHA’s updated Regional and National Loan Committee Limits can be found here.
- What’s next: The updated loan approval thresholds have long been recommended by MBA members and should help improve the financing process, especially for construction and substantial rehab projects.
For more information, please contact Stephanie Milner at (202) 557-2747.
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:
- Relationships Matter: How to turn Today’s Purchaser into Tomorrow’s Refinancer – today, September 8
- CRE Mortgage Risk and What the Pandemic Taught Us – September 20
- State of Non-QM Lending & What You Need to Know Now – September 27
- Empowering Mortgage Servicers with Proactive KPIs – September 29
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.
