MBA Advocacy Update: Regulatory Updates in N.H., Colo.; Lenders Save 5% on Membership Renewal by 8/31; more

New Hampshire Aligns MLO Licensing Standards with SAFE Act

New Hampshire recently enacted HB 1207, which modifies the minimum licensing requirements for a mortgage loan originator (MLO) by reducing the lookback period for certain felony convictions from ten to seven years, aligning state law more closely with the Secure and Fair Enforcement for Mortgage Licensing (SAFE) Act of 2008. 

Why it matters: New Hampshire’s licensing standards aligning with the SAFE Act’s framework follows actions by other states, including Georgia, that have recently revised MLO licensing restrictions that go beyond the SAFE Act’s minimums to more closely align with federal standards.

What’s next: HB 1207 will take effect on October 1, 2026, and guidance from the New Hampshire Department of Banking on other aspects of the new law is available here.

For more information, please contact Liz Facemire, CMB, at (202) 557-2870 or Ainsley Zimmer at (202) 557-2796.

Colorado Department of Law Releases Proposed ADMT Regulations

On Tuesday, the Colorado Department of Law (the Department) released proposed rules to clarify and implement the Colorado Automated Decision-making Technology Act (ADMT Act). The law defines an ADMT and establishes new requirements for both developers and deployers of ADMTs that are used to materially influence a consequential decision. It also gives consumers the right to request and correct inaccurate personal data used by ADMT as well as request human review of a decision.

• The proposed rules explain deployer responsibilities to provide adequate notice to consumers as well as how to process a consumer request.
• Comments are due Friday, September 4. The Department outlines a process that includes a re-proposal in September and final comments due October 26.

Go deeper: Based on MBA’s initial review, the proposed rules will need to be refined to provide clearer guidance the mortgage industry.

• The proposed rules do not provide guidance on what is considered an ADMT or what rises to the level of a consequential decision. This leaves creditors without a clear understanding of what processes are covered by the ADMT Act.
• The proposed rules allow a creditor to provide a notice with the information required under the ADMT Act combined with the information required in an Equal Credit Opportunity Act (ECOA) or Fair Credit Reporting Act (FCRA) adverse action notice. MBA previously recommended in an earlier pre-proposal comment letter that the rule should allow compliance with the adverse action requirements of ECOA and FCRA to constitute compliance with the ADMT Act.
• Although the proposed rules provide some explanation of when a consumer can request human review and reconsideration, questions remain regarding when a creditor can deny a human review because it is “commercially unreasonable.”
• The proposed rules need a clearer distinction between developers and deployers.

What’s next: MBA will solicit feedback from members to comment throughout this rulemaking.  Please note the short frame for comments – September 4!

 To provide feedback on the proposed rule, contact Liz Facemire, CMB (202) 557-2870 or Gabriel Acosta (202) 557-2811.

Please visit the MBA resource center mba.org/stateai for additional information on state AI activities.

Lenders: Save 5%* on Your FY 2027 MBA Membership Renewal

On Fiscal Year (FY) 2027 membership renewal is underway, and MBA members that are lenders can take advantage of a 5% early renewal discount through August 31. 

Renew your company’s MBA membership by the early renewal deadline to secure your savings and continue uninterrupted access to MBA’s advocacy, industry resources, education, networking and member benefits.

Why it matters: Renewing early* saves your company 5% on membership dues and includes additional education benefits, while ensuring your team continues to have access to the resources, connections, and advocacy that support your business and the real estate finance industry.

What’s next: Renew your company’s membership by August 31 to receive the 5% early renewal discount. Contact your MBA Member Relations Director for assistance with your renewal.

*Please note: 5% discount applies to lenders only.

For more information, please contact the MBA Help Desk at (800) 793-6222, ext. 1.

Upcoming MBA Education Webinars on Critical Industry Issues

MBA Education continues to deliver timely 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:

• Using Quality Assurance, Control and Fraud Prevention to Strengthen Loan Operations – August 25
• From Data Chaos to AI-Ready: 3 Use Cases for Loan Documents and How to Implement Them – September 2
• Maximizing Home Equity Without Refinancing – September 8
• Benchmarking for Performance and the Performance Ratios Every Mortgage Banker Must Know – September 10
• Gain Confidence, Efficiency and Savings with Loan Product Advisor (LPA) – September 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.