Christine Chandler Discusses the Servicing Scene in Washington
(Christine Chandler speaking at MBA’s 2025 Commercial/Multifamily Finance Servicing and Technology Conference)
HOLLYWOOD, FLA.–There have been many changes since last year’s Commercial/Multifamily Finance Servicing and Technology Conference, 2025 MBA Chair-Elect Christine Chandler said here in her opening remarks.
Chandler also serves as Executive Vice President, Chief Credit Officer & Chief Operating Officer with M&T Realty Capital Corp. Baltimore.
“You could even say the world has been turned upside down,” Chandler noted. “The 2024 election returned Donald Trump to the Oval Office, buttressed by Republican majorities in the House and Senate. Since taking office, the president has been moving aggressively on his campaign pledges, including sharp reductions in the federal workforce or shutting down government agencies, altogether.”
Chandler said MBA has long argued that regulatory overreach and layers of rules often serve to drive up costs for consumers without addressing the nation’s affordable housing crisis. “At the same time, a lot of the work at HUD, Veterans Affairs, and other agencies help support opportunities to secure the American Dream. The Consumer Financial Protection Bureau was slated for elimination. MBA has objected to many Bureau policies over the years. However, its sudden disappearance would have unintended consequences.”
“Ironically, we need people with expertise and experience in place at the Bureau to revise and reform certain rules adopted in previous administrations,” Chandler said. “For example, the Bureau announced it would revisit the 1071 rule, and MBA is advocating that they clarify that investment property lending is excluded from reporting.”
“The right rules provide stability,” she said. “Wrong rules – or no rules at all – do the opposite.”
Chandler said the size and scope of government agencies involved in housing finance will remain an evolving project, noting some staff reductions and program cuts have been reversed or blocked by federal courts.
“MBA has pledged to work with the Administration – to be a resource and partner in crafting sound policies whenever possible – or to raise objections or concerns about policy proposals whenever necessary,” she said. “We believe private communications – whether a one-on-one conversation with a senior official or raising questions or concerns in private meetings – is more effective than issuing alarmed statements through the media. And that is exactly what MBA’s leadership has been doing.”
“MBA President Bob Broeksmit likens this approach to a swan. It looks graceful moving across the water. But just below the surface it is paddling fast and furious,” Chandler said.
Turning to some recent wins, Chandler said HUD updated underwriting standards in January for some of its construction programs and for certain properties targeted to middle-income households, “thanks in no small part to MBA’s advocacy.”
“We are confident this will result in boosting production of much-needed rental housing – perhaps tens of thousands of units over the next three years.”
In addition, in March, HUD announced a six-month delay (until September 10, 2025), on the implementation of its final rule on Energy Efficiency Building Standards. The rule requires any new construction with FHA-insured and Department of Agriculture-guaranteed financing to use significantly newer building codes that most states have yet to adopt. In fact, only five U.S. states have adopted the 2021 code. 32 states are still on the 2009 code or earlier.
“The six-month delay was among recommendations MBA made to HUD,” Chandler added. “The delay is a step in the right direction, but MBA believes that reversing this policy is the best way to preserve affordable FHA financing for new homes and apartments. We are hopeful we will also soon see a reversal of the Federal Flood Risk Management Rule, which has caused significant concerns for HUD multifamily housing.”
In March, the FDIC announced it intends to rescind the Community Reinvestment Act (CRA) provisions from October 2023 final rule. “While that final rule included several MBA recommendations and requested clarifications, several banks argued the new rule amounted to government overreach. The rule was also the subject of litigation,” Chandler said. “It is unclear for now whether the federal agencies will issue a new proposal on modernizing the current CRA rules. The rescission could encourage more states to consider their own CRA rules for state-chartered institutions, including independent mortgage bankers and credit unions. The result could be a fragmentation of CRA standards, which would be confusing. A unified approach to CRA modernization, with updates reflecting changing technology and business models, makes more sense. We will continue to advocate for such.”
Last month, the Consumer Financial Protection Bureau agreed to reopen Dodd-Frank Section 1071 Rulemaking. Chandler noted that MBA has urged the Bureau since 2023 to narrow the rule’s scope and exempt loans to finance income-producing investment properties from Dodd-Frank reporting requirements. “Investment property lending is quite different from other kinds of small business lending,” she said. “We will continue to recommend the repeal, or narrowing of the scope, either legislatively or regulatorily.”
“Finally, just last month HUD reinstated the policy of allowing non-critical repairs healthcare related properties to be included in refinances,” she said. “This makes sense. Non-critical repairs are not unnecessary repairs. MBA will continue to work with HUD to ensure its healthcare programs are running appropriately.”
Chandler discussed a looming tax battle in Congress. “While we are quietly and effectively interacting with new agency heads and staff in the executive branch, Congress is gearing up for a major tax bill. Provisions enacted in 2017 are expiring this year,” she said. “MBA has reinstituted a Board-level Tax Task Force, which I chair. One of our top issues is the Low-Income Housing Tax Credit, the deferred tax treatment of income/sales related to Mortgage Servicing Rights, extending the expiring 199A small business “pass-through” deduction, maintaining a differential between the tax treatment of capital gains versus ordinary income, and reinstating the deductibility of mortgage insurance premiums.”
She said the tug-of-war in Congress is centered on how to reduce taxes without adding significantly to the nation’s debt and deficits. “We will be vigilant and fight hard to retain tax policies that strengthen a competitive and pro-growth real estate marketplace.”
Another big issue on the horizon is ending the conservatorship of Fannie Mae and Freddie Mac, now in its seventeenth year. “Legislation will likely be needed to move the GSEs into a new era, Chandler said. “The transition to a post-conservatorship era for the GSEs must be handled with precision to minimize market disruption and uncertainty. Whenever that happens, MBA will play a significant and constructive role to ensure a vibrantly competitive primary market that delivers mortgages at competitive rates for consumers.”
“We are living through a tumultuous time,” Chandler concluded. “The fate of agencies our industry has long worked with is an open question. A possible trade war has the Federal Reserve wondering whether to base decisions on interest rates on expectations about a recession or an upsurge in inflation – or both.” She stresses the importance of MBA members being actively engaged in our advocacy efforts. “At this year’s National Advocacy Conference, there were over 600 attendees representing 43 states. That was a great show of force–we need to keep the momentum going!”
