CREF Policy Update: House Financial Services Committee Holds Hearing with Prudential Regulators; MBA, Trades Call for Bank Capital Reform

House Financial Services Committee Holds Hearing with Prudential Regulators; MBA, Trades Call for Bank Capital Reform

Last Tuesday, the full House Financial Services Committee held a hearing titled, “Oversight of the Prudential Regulators.” 

• The high-profile hearing foreshadowed potential regulatory changes that could emerge from the Trump administration – with government witnesses (from the Fed, OCC, FDIC, and NCUA) emphasizing a shift toward risk-aligned capital frameworks, including a comprehensive review of mortgage capital treatment, securitization charges, and leverage ratios. These adjustments (as discussed) will aim to improve clarity and reduce unnecessary burdens while preserving safety and soundness—critical for liquidity in residential and multifamily markets.
• Find the full hearing summary here and watch the live hearing here

Why it matters: Lawmakers pressed for modernization of tailoring thresholds and supervisory categories, noting that outdated asset triggers distort growth incentives for community and regional banks. Changes could positively influence single-family warehouse lending costs, credit availability for multifamily projects, and more. Regulators also addressed deposit insurance reform and stablecoin-related deposit flight risks, both of which affect funding stability for lenders and servicers. MBA signed and contributed to a joint statement with other leading financial trades that was entered into the official hearing record.

Go deeper: As recommended by MBA, a portion of the joint trades statement emphasized that “commercial banks constitute our nation’s largest source of commercial and multifamily real estate financing. In addition, they are significant holders of single-family mortgage assets and critical liquidity providers to the secondary mortgage market. Higher bank capital requirements can harm single-family, multi-family, and commercial real estate finance by hindering lending, reducing jobs, and negatively affecting local economies, particularly hurting first-time and low-income homebuyers. Capital requirements are an added cost borne by homeowners and tenants in an already challenging housing market. These are important considerations for regulators to weigh as they conduct economic analysis to determine the appropriate levels of capital.”

What’s next: MBA will stay engaged as regulators recalibrate bank capital rules (including the Basel III Endgame proposal) that impact commercial and multifamily mortgages, mortgage servicing rights, risk weighting, capital allocation, risk-based pricing, and operational resilience across the banking spectrum.

For more information, please contact  Madisyn Rhoneat (202) 557-2741, and Rachel Kelley at (202) 557-2816.

House Financial Services Committee Holds Hearing on Housing; Negotiations Continue on ROAD to Housing Act and NDAA Inclusion

On Wednesday, the House Financial Services Committee (HFSC) held a full committee hearing titled, “Building Capacity: Reducing Government Roadblocks to Housing Supply,” where panel members examined the barriers impacting housing supply and development, financing, and other issues such as zoning, compliance costs, bank capital standards, and insurance premiums.

• Find the full summary here and watch the full hearing here.

Why it matters: HFSC Chairman French Hill (R-AR) announced his intention to create a housing and banking legislative package at his panel’s expected two-day markup on December 16 and 17. Hill stated the package will prioritize cutting red tape, encouraging innovation and investment, streamlining regulatory processes in an effort to create a more predictable environment for builders, lenders, buyers, and renters.

• The committee “noticed” 41 bills as part of Wednesday’s hearing, including the MBA-led, H.R. 6132, The Housing Affordability Act, introduced by Representatives Monica De La Cruz (R-TX) and Ritchie Torres (D-NY). The bill, which mirrors companion Senate legislation modified within the Senate’s ROAD to Housing Act, would amend the National Housing Act and update existing loan limits to more accurately reflect current multifamily construction costs. The bill would also peg those costs to an index that more accurately tracks those costs as compared to the Consumer Price Index (the index currently authorized for the program). MBA has consistently called for increasing the loan limits and signed onto a coalition letter urging support and passage of this important legislation to help increase multifamily housing supply.

What’s next: MBA will continue to monitor discussion in both the House and Senate as negotiations continue on the ROAD to Housing proposal and/or any newly-evolving House housing package (per Chairman Hill’s comments). 

For more information, please contact  Madisyn Rhoneat (202) 557-2741, Rachel Kelley  at (202) 557-2816, Bill Killmer at (202) 557-2736 or George Rogers at (202) 557-2797.

Federal Banking Regulators Issue NPR on the Community Bank Leverage Ratio

Last Monday, the three federal banking regulators (the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation – the “Regulators”) jointly issued a notice of proposed rulemaking on the Community Bank Leverage Ratio (CBLR).

• The proposal would lower the CBLR framework for qualifying community banks and community bank holding companies from 9% to 8%, consistent with the threshold provided in the legislation that established the framework (section 201 of the Economic Growth, Regulatory Relief, and Consumer Protection Act).
• The proposal would also extend the length of time, from two to four quarters, that certain community banks can remain in the CBLR framework while not meeting all of the qualifying criteria for the framework.

Why it matters: MBA has long supported the CBLR framework as an important tool for providing meaningful regulatory relief for qualifying community banks by removing the requirement for calculating and reporting risk-based capital ratios for banks that opt in. To be eligible to opt in, a community bank must be at or above the established capital ratio (determined by calculating the ratio of tangible equity capital to average total consolidated assets). 

Go deeper: At the time the CBLR was established in 2017, MBA strongly urged the Regulators to set the ratio at no higher than 8% and to provide a longer timeframe for a bank that falls out of compliance to either get back in compliance or exit the framework. MBA called for a lower ratio in its October 2025 comment letter to the Regulators on their review of “Regulatory Burdens on Community Banks.”

• As MBA has consistently noted, an 8% ratio (rather than the 9% that was proposed (and adopted) would encourage broader adoption or opt in to the CBLR framework, and thereby help reduce burdensome capital requirements for many community banks.

Shortly before Monday’s Federal Register publication, Acting House Financial Services Chairman Travis Hill praised the proposal, echoing MBA’s view that the proposed 8% ratio and extended grace period would encourage broader community bank participation in the CBLR framework and give banks sufficient time to regain compliance or transition to risk-based capital standards.

What’s next: MBA will submit comments on the proposed rulemaking by the January 30, 2026, deadline.

For more information, please contact John Lammle at (202) 557-2789, Fran Mordi at (202) 557-2860 or Monique Ellis at (202) 557-2856.

MBA Joins Joint Trades Letter Urging Long-Term NFIP Reforms

Last Tuesday, MBA and a coalition of 14 major trade organizations representing insurance and financial institutions urged congressional leaders in a letter to execute a long-term reauthorization of the National Flood Insurance Program (NFIP). 

Why it matters: “As stakeholders representing real estate, insurance, lending, and state and local governments, we urge Congress to act decisively to ensure stability and certainty for the millions of Americans who rely on this vital program to protect their families and properties from flooding—the nation’s most common and costliest natural disaster,” the organizations wrote in the letter

Go deeper: The federally funded insurance program has had 34 short-term reauthorizations since 2017, with no large-scale change, even as lawmakers have repeatedly called for comprehensive improvements to the program. Additionally, the recent government shutdown allowed the NFIP to lapse for more than a month, the longest period the program has ceased writing and renewing policies in almost a decade. The program is up again for reauthorization by Jan. 30, 2026.

What’s next: MBA will continue to work with these coalition partners (and others) to advocate for a longer-term reauthorization of the NFIP that adds certainty to the application of the program – and extends well beyond the current fiscal year.

For more information, please contact  Madisyn Rhone at (202) 557-2741, Rachel Kelley at (202) 557-2816, Bill Killmer at (202) 557-2736 or George Rogers at (202) 557-2797.

Renew Your MAA Membership for 2026

Because of MAA’s grassroots advocates like you, MBA secured several legislative wins in 2025, including major tax legislation that preserved pro real estate finance provisions. In 2026, the need for continued, robust industry support is crucial as MBA addresses the future of the housing GSEs, TRIA Reauthorization, and much more.

As the year comes to a close, please take 30 seconds to join or renew your annual MAA membership.

MAA members receive many benefits, including:

• timely calls to action at all government levels;
• real-time news alerts impacting our industry;
• quarterly newsletters packed with policy updates; and,
• an invitation to MAA’s quarterly webinar series

Why it matters: MAA is a FREE network that unites all industry advocates and allows you to have an active role in shaping legislation and regulations. You are the experts, and your voice is needed to share the vital work we do. We are LOUDER together!

What’s next: Attend the National Advocacy Conference (NAC), MBA’s largest in-person advocacy event on April 14-15, designed to let MBA members share their policy concerns face-to-face with elected officials and make a collective impact on behalf of our industry. Register NOW!

For more information, please contact maa@mba.org or Margie Ehrhardt at (202) 557-2708.

MBA and NYMBA Oppose NYC Council’s Community Opportunity to Purchase Act

In a letter sent to the New York City Council President , MBA and the New York Mortgage Bankers Association (NYMBA) voiced strong opposition to the Council’s proposed Community Opportunity to Purchase Act (Intro 902-A) or COPA, which would give qualified nonprofits and tenant groups the first opportunity to purchase multifamily rental buildings when they come up for sale.

Why it matters: The letter warns that the COPA measure could stifle investment and new development by introducing lengthy sale delays —requiring sellers to provide 180 days’ notice and limiting competing offers —while dampening property values and discouraging for-profit buyers with experience in maintaining and improving affordable housing.

• COPA would exacerbate the acute affordable housing problem by deterring much-needed private capital and slowing redevelopment at a time when NYC faces intense housing pressures.

What’s next: MBA will continue to work with the NYMBA to oppose this legislation should it pass the Council.

For more information, please contact William Kooper (202) 557-2737 or Megan Booth (202) 557-2740.

Commercial and Multifamily Mortgage Delinquency Rates Mixed in Third-Quarter 2025

Commercial mortgage delinquencies were mixed in the third quarter of 2025, according to MBA’s latest Commercial Delinquency Report, released last Thursday.

What they are saying: “Commercial mortgage delinquencies increased for CMBS and GSE loans in the third quarter and decreased slightly for banks and life companies as pressures remain in certain segments of the market,” said Reggie Booker, MBA’s Associate Vice President of Commercial Real Estate Research. “Property values have stabilized, but loan performance is impacted by shifting property fundamentals, including higher vacancy rates and slower rent growth. Delinquency performance remains highly dependent on property type and loan structure.”

To download the report, click here.

For more information, please contact Reggie Booker at (202) 557-2863.

mPact Local Fundraiser Supports MBA Opens Doors Foundation

Last Wednesday, mPact held a fundraiser in Dallas benefiting the MBA Opens Doors Foundation. The event was proudly sponsored by Bank United, Northmarq, Trimont, and Apprise and brought together 50 industry professionals for an evening of networking and purpose.

• The fundraiser featured an insightful market panel discussion with leaders Jay Donaldson (Northmarq), Rob Walton (Trimont), Ben Stacks (Bank United), and Ben Herd (Haynes Boone) who shared perspectives on current trends and challenges shaping commercial real estate.

Why it matters: The mPact fundraiser benefited the MBA Opens Doors Foundation, which provides mortgage and rental assistance to families with critically ill or injured children. Events like this are vital for connecting young professionals with industry leaders — fostering mentorship, knowledge-sharing, and collaboration, and helping the next generation build relationships and gain insights that will shape the future of CRE. Participants also demonstrated their commitment to making a tangible difference in people’s lives beyond the business of real estate.

What’s next: mPact is all about engaging the next generation of CRE leaders. If you’re passionate about networking, professional growth, and giving back, now is the perfect time to get involved with mPact. Learn more about mPact here.

For more information, please contact Kelli Burke at (202) 557-2742.

Upcoming MBA CREF Council and Committee Meetings

MBA’s CREF Councils and Committees are a key way to connect to everything MBA has to offer around policy, advocacy, market intelligence and research, education, and networking. Councils and Committees are built around specific capital sources and serve as an opportunity for you to join other commercial real estate finance professionals to hear from experts, discuss opportunities and challenges, and connect with peers.

Upcoming virtual meetings include:

Servicer Council: Jan. 15
Private Credit Council: Jan. 21
Insurance Company Council: Jan. 22
All Council In-person Meet-up: Feb. 8

For more information, click on the links above and/or contact Kelli Burke at (202) 557- 2742.

Upcoming MBA Education Webinars on Critical Industry Issues

MBA Education continues to deliver timely commercial/multifamily and single-family programming that covers the spectrum of challenges, opportunities, obstacles and solutions pertaining to our industry. Below, please see a list of upcoming and recent webinars – all complimentary to MBA members:

Commercial/Multifamily Capital Markets and Securitization – Dec. 16
External CMF Benchmarking Requirements – Jan. 14
Internal CMF Benchmarking Requirements – Feb. 18
Introduction to Commercial Mortgage-Backed Securities – April 8
Basics of Commercial Loan Closing and Loan Documentation – May 12

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

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