CREF Policy Update: Trump Administration Releases Additional Details on FY 2026 Budget Proposal
Trump Administration Releases Additional Details on FY 2026 Budget Proposal
Recently, the Trump administration released additional details of its Fiscal Year (FY) 2026 budget proposal. Each year, the president’s budget request, otherwise known as its “wish list” that carries no force of law by itself, provides a blueprint for the Administration’s priorities as Congress traditionally kicks off its appropriations process for the new fiscal year.
Why it matters: The budget proposal calls for a reduction in non-defense discretionary spending by 22% (on average). However, the proposal would cut the Department of Housing and Urban Development’s (HUD) total funding by 44%. Of most concern, it makes significant proposed cuts to HUD’s subsidy programs with recommendations to turn the voucher programs – both tenant-based and project-based, and elderly and disabled – as well as CDBG, HOME, Choice Neighborhoods, and others – into block grants to the states.
• Last year, the estimated cost of the voucher programs alone was $54 billion, and the budget proposes a total of $36.2 billion for all the proposed block granted programs. If enacted, the recommendations could have serious implications for Low-Income Housing Tax Credit (LIHTC) and affordable projects that rely on rental assistance payments.
What’s next: As is customary, MBA is engaging with leaders at the federal housing agencies and the Congress on FY 2026 appropriations and funding levels. Preliminarily, we have been encouraged by their receptiveness and commitment to maintaining and/or promoting new solutions that bolster housing supply, improve affordability for both renters and borrowers, increase access to sustainable homeownership, and lead to positive outcomes for our members and their businesses.
For more information, please contact Bill Killmer at (202) 557-2736 and Megan Booth at (202) 557-2740.
Acting Comptroller Hood Details Current Banking Industry Regulatory Landscape
Last Tuesday, Acting Comptroller of the Currency (OCC) Rodney Hood delivered a speech at the U.S. Chamber of Commerce Capital Markets Forum where he discussed several policy issues affecting the banking industry. Acting Comptroller Hood highlighted OCC’s efforts to expedite bank-fintech partnerships, encourage engagement with the digital asset industry, advance financial inclusion, and reform existing regulations to promote economic growth. His speech touched on issues affecting banks across all asset sizes, including:
• The withdrawal of the OCC’s proposal on climate-related risk management principles for large banks and efforts to cease examining for “reputation risk.” These were cited as concrete efforts to promote growth in the banking system.
• On Basel III implementation, Acting Comptroller Hood noted, “I was heartened to see consensus from the international community that the U.S. proposal had gone beyond what was necessary. As we continue interagency deliberations, I will remain committed to a capital framework that supports resilience—but does not constrain growth.”
• Acting Comptroller Hooded added that supplementary leverage ratio (SLR) reform is being discussed, and the SLR should function as a backstop while not unnecessarily restricting lending.
Why it matters: Last fall, MBA agreed with Federal Reserve leadership that a re-proposal of the Basel III endgame was necessary. In its 2024 comment letter, MBA advocated for CRE-specific issues related to key definitions and treatment of defaulted loans. Additionally, MBA partnered with several CRE trades in a joint letter to express concerns around the treatment of securitization and risk-weights.
What’s next: MBA will continue to monitor the implementation of Basel III standards and SLR reform to ensure its members’ voices are adequately reflected in the respective final proposals.
For more information, please contact John Lammle at (202) 557-2790.
HUD Proposes Rescission of Affirmative Fair Housing Marketing Regulations
Last Tuesday, HUD proposed a rescission of the Affirmatively Furthering Fair Housing (AFFH) Marketing regulations. This follows an Interim Final Rule issued in early March to return to the original understanding of AFFH, establishing that HUD grantees must agree to a general commitment to promote fair housing.
Why it matters: A rescission of this policy would remove the requirement that participants using FHA multifamily and certain other HUD housing programs complete and submit a form outlining its affirmative fair housing marketing plan. Program participants should continue to affirmatively further fair housing as and to the extent required by the Fair Housing Act.
What’s next: MBA is committed to fair and equitable access to credit. MBA also agrees with HUD’s determination that the existing AFFH compliance procedures are extensive and burdensome. Comments to HUD are due by July 3, 2025.
For more information, please contact Megan Booth at (202) 557-2740.
Commercial and Multifamily Mortgage Delinquency Rates Increased in First-Quarter 2025
Commercial mortgage delinquencies increased in the first quarter of 2025, according to MBA’s latest Commercial Delinquency Report, released last Tuesday.
What they are saying: “Commercial mortgage delinquencies rose across all major capital sources in the first quarter of 2025, reflecting growing pressure on certain property sectors and loan types,” said Reggie Booker, MBA’s Associate Vice President of Commercial Real Estate Research. “While delinquency rates remain relatively low for most investor groups, the uptick in CMBS delinquencies signals heightened stress in parts of the market that lack refinancing options or other challenges.”
To see the full report click here.
For more information, please contact Reggie Booker at (202) 557-2863.
Participate in MORPAC Action Week, June 23-27!
On June 23, MORPAC, MBA’s Political Action Committee, officially will kick off its annual Action Week. As the only federal PAC that represents the entire real estate finance industry, MORPAC provides access to candidates for federal office who will shape policies that impact the interests of MBA’s CREF members.
• MORPAC is aiming to raise $225,000 during its 2025 Action Week – from at least 20 participating member companies.
• We need your help! Sign up now to make a bigger impact by running a MORPAC campaign and encourage your employees to directly participate in the political process.
Why it matters: MORPAC is a powerful tool for driving policy change, providing MBA members with a platform to amplify their voice, educate decisionmakers, and channel financial resources to support pro-industry candidates to advance MBA’s legislative agenda.
What’s next: If you are interested in getting involved during MORPAC Action Week, please fill out this link.
For more information, please contact Erin Reilly at 202-557-2751.’
Register: MBA’s mPact Summit on August 5
Meet us in the nation’s capital for a full day of career development and networking on Tuesday, Aug. 5, 2025. Back by popular demand, this event is built by young professionals in the real estate industry, for young professionals, who are focused on helping you get to the next level.
Why it matters: The mPact Summit isn’t just about career tips, it’s about empowerment, connection, and growth! The summit will provide the tools, confidence, and network to thrive and help you become tomorrow’s leaders.
Register now!
For more information, please contact Jacky Salazar
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, obstacles and solutions pertaining to our industry. Below, please see a list of upcoming and recent webinars – all complimentary to MBA members:
• MBA Roundtable with CMF Council Leadership – June 12
• Decoding Blanket Property Insurance for Commercial and Multifamily Properties – June 26
• Essential Overview of Commercial/Multifamily Business Income Insurance – July 15
• Navigating Coverage and Risk for Commercial Catastrophic Insurance – July 21
• Trends in Commercial Non-Bank Lending: Evolving Strategies & Creating Operational Advantages – Sept. 9
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.
