CREF Policy Update: MBA’s Jamie Woodwell Represents CRE Industry Before Federal Reserve; MBA Responds to CFPB Information Request on HMDA
MBA’s Jamie Woodwell Represents CRE Industry Before Federal Reserve
Last Thursday, MBA’s Jamie Woodwell, Senior Vice President of Commercial/Multifamily Policy and Strategic Industry Engagement, represented the CRE industry before the Federal Reserve’s Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) public meeting.
• Watch a replay of the meeting here.
• The Federal Reserve conducted outreach meetings to obtain industry to identify outdated, unnecessary, or unduly burdensome regulations affecting insured depository institutions.
• Woodwell highlighted areas where regulations are hindering depositories, including: the Community Reinvestment Act (CRA), outdated bank capital requirements, Supervisory Guidance pertaining to CRE lending, and nuances surrounding FR Y-14 reporting.
• Federal Reserve staff acknowledged that their conversations with panelists will be considered when reviewing federal banking regulations.
Why it matters: Industry participants rarely have opportunities to appear before supervisory banking staff to discuss the implications of current policies. The EGRPRA public meeting serves as an opportunity, once a decade, for industry participants to formally share feedback with their banking supervisors. Candid dialogue benefits both industry and banking supervisory staff and encourages reform that will help industry participants while ensuring financial stability.
What’s next: MBA will continue to work with members for feedback on how to best represent the industry before the Federal Banking Agencies.
For more information, please contact John Lammle at (202) 557-2789.
MBA Responds to CFPB Information Request on HMDA
Last Thursday, MBA sent a letter in response to a Request for Information (RFI) from the Consumer Financial Protection Bureau (CFPB or the Bureau) pertaining to the Home Mortgage Disclosure Act (HMDA) and its implementing regulations, Regulation C.
Why it matters: The CFPB requested comments on whether the collection of information is necessary for the proper performance of the functions of the CFPB, including whether the information has practical utility and the accuracy of the CFPB’s estimate of the burden of the collection of information. Additionally, the Bureau asked for comments on the validity of the methods and the assumptions used, ways to enhance the quality, utility, and clarity of the information to be collected, and ways to minimize the burden of the collection of information on respondents.
• In the letter, MBA applauded the CFPB’s decision to evaluate the effectiveness of HMDA and Regulation C in meeting its stated goals, purposes, and objectives. MBA also suggested several ways that the CFPB can minimize the burden of the collection of information on respondents.
Go deeper: Specifically, MBA recommended the following changes to Regulation C:
• Exempting Multifamily/Commercial Loans from HMDA Reporting Requirements;
• Raising the Loan Reporting Threshold to 100 loans from 25;
• Defining what Actions Constitute a HMDA Violation;
• Removing Non-Useful and Burdensome Data Points from Reporting Requirements;
• Remove the Requirement for Quarterly HMDA Reporting;
• Removing the Requirement to Report Loan Assumptions; and,
• Reconsidering Guidance for Peer Comparison using Publicly Available HDMA Data;
What’s next: MBA will keep members informed about next steps.
For more information, please contact Megan Booth (202) 557-2740, Justin Wiseman at (202) 557- 2854, or Alisha Sears at (202) 557-2390.
Commercial and Multifamily Mortgage Delinquencies Mixed in Fourth-Quarter 2025
Commercial mortgage delinquencies were mixed in the fourth quarter of 2025, according to MBA’s latest Commercial Delinquency Report, released last Tuesday.
• Click here to download the latest report.
What they’re saying: “Commercial mortgage performance remained generally stable in the fourth quarter of 2025, with most capital sources displaying modest improvements in delinquency rates,” said Reggie Booker, MBA’s Associate Vice President of Commercial Research. “Delinquencies for Fannie Mae loans increased for the second straight quarter and are now above the midpoint of their historical range going back to 1996. While elevated stress in CMBS continues to reflect ongoing challenges in certain property sectors, overall loan performance remains resilient. In 2026, investors will be closely watching how refinancing pressures and economic conditions shape credit performance across capital sources.”
For more information, please contact Reggie Booker at (202) 557-2863.
Colorado Enacts MBA-Supported HOME Act to Streamline Housing Development on Qualifying Properties
Colorado has enacted HB26-1001, the “Housing Opportunities Made Easier” (HOME) Act, which will require local governments to allow residential development on certain qualifying properties beginning Dec. 31, 2027.
• The law covers properties owned by nonprofits, school districts, colleges and universities, housing authorities, and transit entities, and is designed to reduce local barriers to new housing construction.
Why it matters: The measure is part of a broader state effort to address housing supply constraints through land use reform and could support additional multifamily and mixed-use development.
Go deeper: MBA is a founding member of the Housing Solutions Coalition, which supported the bill and launched an ad campaign saying it will help unlock underutilized land for housing, support working families, and create more predictable review processes for new development. The law will help expand opportunities for financing new housing projects while also underscoring the growing role states are playing in shaping local development policy.
What’s next: MBA will be watching how local governments carry out the new requirements and whether the law produces a measurable increase in housing production.
For more information, please contact William Kooper (202) 557-2737 or Megan Booth (202) 557-2740.
Key House Subcommittee Holds Hearing on High Cost of Flooding/Mitigation
Last Thursday, the House Financial Services Committee’s Subcommittee on Housing and Insurance held a hearing titled, “Mitigation and Multiple Loss Properties: Factors Influencing the High Cost of Flooding.” The witnesses were: Dr. Alicia Puente Cackley, Director, Financial Markets and Community Investment, U.S. Government Accountability Office; Dr. Diane Horn, Specialist in Flood Insurance and Emergency Management, Congressional Research Service; Mr. Steve Ellis, President, Taxpayers for Common Sense; Mr. Joel Scata, Senior Attorney, Natural Resources Defense Council; and Ms. Samantha Medlock, Founder and President, Climate Risk Advisors.
• The hearing explored the increasing frequency and severity of flooding disasters, the long-term benefits of mitigation, and the impact of multiple-loss properties on the National Flood Insurance Program (NFIP) delivering quality results.
• A summary of the hearing can be found here.
Go deeper: Republicans concentrated on the NFIP’s financial and operational challenges and the importance of mitigation. Some Republicans called for the restriction or elimination of NFIP coverage for severe repetitive loss properties. Democrats focused on the disproportionate impact of flooding on low-income communities and upon concerns with the Trump administration’s efforts to cut both community grants and the FEMA workforce.
What’s next: As flood insurance issues continue to be considered by Congress, MBA will persist in our call for the elimination of the mandatory flood insurance purchase requirement for commercial properties. This will allow businesses to manage flood risk with more agility and on their own individual terms without impacting the financial stability of the NFIP. MBA also will continue its advocacy for a longer term NFIP reauthorization in order give the flood insurance marketplace certainty and stability.
For more information, please contact Rachel Kelley at (202) 557-2816 or Jeremy Green at (202) 557-2849.
Get Ready for NAC: Join Our Prep Webinars
MBA’s National Advocacy Conference is just around the corner, and now is the perfect time to secure your spot. Once you’re registered for the conference, take advantage of our two preparatory webinars designed to help you arrive informed, confident, and ready to advocate effectively on Capitol Hill.
• Issues Briefing Webinar Thursday, April 2 | 3:00–4:00 PM (ET) Hear the latest updates on key residential and commercial/multifamily policy priorities so you can deliver a strong, informed message during your Hill meetings.
Why it matters: Your voice carries weight. NAC is your opportunity to speak directly with lawmakers about the issues shaping the real estate finance industry. These webinars ensure you’re fully prepared to make the most of those conversations—armed with the latest policy insights and the confidence to advocate effectively.
What’s next: After attending the prep webinars, you’ll receive final event details, meeting schedules, and on‑site guidance to help you navigate NAC with ease. We’ll make sure you’re ready for a productive and impactful experience in Washington.
For more information, email nac@mba.org or contact Jamey Lynch at (202) 557-2818 or Erin Reilly at (202) 557-2751.
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:
• Bank Council: April 8
• Life Company Council: April 9
• Agency Council: April 9
• FHA Spring Roundtable: April 13-14
• Private Credit Finance: April 23
• Commercial Council: April 29
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:
• Introduction to Commercial Mortgage-Backed Securities – April 8
• Basics of Commercial Loan Closing and Loan Documentation – May 12
• HUD’s Role in Multifamily Financing – May 20
• Mastering Commercial Insurance Modeling: Key Insights and Applications – May 21
• Understanding Tax-Exempt Private Activity Bonds in Affordable Housing Finance – June 12
• Fundamentals of Commercial Insurance Issues and Problems – July 15
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.
