Home > CMF Newslinks > MBA Commercial/Multifamily NewsLink Thursday July 16 2026

CREF Policy Update: HUD Proposes to Rescind Flood Requirements

July 14, 2026

Please note: The 21st Century ROAD to Housing Act, which passed the House and Senate in late June, became law on Saturday.  

HUD Proposes to Rescind Flood Requirements

Last Thursday, the Department of Housing and Urban Development (HUD) published a proposed rule to rescind the Federal Flood Risk Management Standards (FFRMS) for FHA-insured properties.

  • The current rules went into effect in 2025 and have required use of a Climate-informed Science Approach (CISA) for determining location in a floodplain. However, CISA maps are not available in most of the country, making compliance with the rule very challenging and costly.

Why it matters: The rule limited construction and substantial rehabilitation in many communities and added significant costs to projects in those areas. HUD’s new proposal retains some of the positive changes to floodways on FHA-insured properties.

What’s next: Comments on the proposal are due by September 8, 2026. MBA will work with members to ensure a robust response supporting the rescissions.

For more information, please contact Megan Booth at (202) 557-2740.

Trump Administration Publishes Spring 2026 Regulatory Agenda

Last week, the Trump administration published its Spring 2026 Unified Agenda of Regulatory and Deregulatory Actions, outlining the regulatory actions that federal administrative agencies plan to issue over the next six months.

Why it matters: The rules and proposals published by federal agencies can have significant impacts on lenders and borrowers. The full lists are now available for the Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), the federal banking agencies (FDIC, OCC, and Federal Reserve), the Department of Housing and Urban Development (HUD), the Federal Communications Commission (FCC) and the Federal Trade Commission (FTC).

Go deeper: Notable and/or new activities MBA spotted in the Spring 2026 agenda include:

  • Final rule rescinding Affirmative Fair Housing Marketing Regulations (HUD)
  • Proposed rule making changes to the three-year rule and bathroom rule in 232 skilled nursing facilities (HUD)
  • Proposed rule to rescind the Federal Flood Risk Management System requirements (HUD)
  • Interim final rule to revise HUD’s noise abatement and control regulations (HUD)
  • Proposed rule to Permanently Renew and Enhance Opportunity Zones (Treasury)
  • Final rule on the Community Reinvestment Act (Federal Reserve, OCC, FDIC)
  • Proposed rule to revise large bank capital requirements (“Basel III”)  (Federal Reserve, OCC, FDIC)
  • Proposed rule to revise and modernize the risk-based capital framework applicable to most U.S. banks (“Standardized Approach”) (Federal Reserve, OCC, FDIC)
  • Proposed rule to adjust the community bank leverage ratio framework (Federal Reserve, OCC, FDIC)

What’s next: MBA will work with members to monitor and respond to proposals put forth by the government agencies that impact residential, multifamily, and commercial lending activities.

For more information, please contact Megan Booth at 202-557-2740 and John Lammle at (202) 557-2789.

California Air Resources Board to Hold Public Workshop on GHG Reporting Requirements

On July 21, the California Air Resources Board (CARB) will hold a public workshop as part of its development of reporting requirements related to greenhouse gas emissions, including those related to loans backed by commercial real estate.

Go deeper: California Senate Bill (SB) 253 requires companies with revenues of more than $1 billion that do business in California to disclose their greenhouse gas emissions (GHG). The law includes Scope 3 GHG emissions, which are indirect emissions that occur in the upstream and downstream value chain and, for lenders, can include emissions tied to properties they lend on. CARB is developing rules to implement the reporting requirements.

  • Staff will provide an update on regulatory concepts for Scope 1 and 2 greenhouse gas (GHG) emissions reporting requirements for 2027 and beyond, including data assurance. Staff will also discuss CARB’s proposed approach for Scope 3 emissions reporting beginning in 2027.

Why it matters: MBA has provided input to CARB about Scope 3 requirements, including in a letter, arguing, “We want to thank CARB for its outreach and its interest in getting these rules right. Getting things wrong risks imposing significant costs while producing disclosures that are inconsistent, unreliable, and of limited decision-making value, an outcome that has already been observed in other jurisdictions and corrected through the introduction of flexibility, phased implementation, and sector-specific approaches.”

What’s next: The Workshop will take place Tuesday, July 21, 2026, from 9:30 a.m. to 12:30 p.m. (Pacific Time).

For more information, please contact Jamie Woodwell at (202) 557-2936 or Megan Booth at 202-557-2740.

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. Visit www.mba.org/yourCREF to find out more.   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:

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:

  • Ditching the Clipboard: Modernizing Loan Inspections and Compliance in Commercial Real Estate – Aug. 26
  • Decoding Blanket Property Insurance for Commercial and Multifamily Properties – Sept. 10
  • AI in Commercial Real Estate Finance: The AI-Powered Originator and Relationship Manager – Oct. 5
  • AI in Commercial Mortgage Finance: Intelligent Deal Screening and Pre-Underwriting – Nov. 2

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.

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