MBA Advocacy Update: GSEs Grant UAD 3.6 Implementation Flexibility, Publish Aligned LLPA Grid; SBC Holds FHA Commissioner Nominee Matt Jones Hearing; MBA Survey Findings on Industry AI Adoption; more

GSEs Grant Temporary Flexibility on UAD 3.6 Implementation

On Wednesday, the Federal Housing Finance Agency (FHFA) and Fannie Mae and Freddie Mac (the GSEs) announced (here and here) that approved lenders may apply for a temporary exception to the Uniform Appraisal Dataset (UAD) 3.6 appraisal delivery deadline of November 2 — a move that follows concerns MBA and its members raised with the GSEs about readiness across the broader appraisal ecosystem.

• MBA and its members have spent the past several months working with the GSEs to support a smooth transition, but raised concerns that gaps in readiness among appraisers, AMCs, and technology providers could lead to higher costs, appraisal delays, and disruptions for borrowers, particularly in rural markets.
• Under the temporary exception, lenders will be permitted to submit appraisals using either UAD 2.6 or UAD 3.6 through May 19, 2027.

What they’re saying: In a press statement, MBA President and CEO Bob Broeksmit, CMB, said, “MBA has had extensive engagement with GSE leadership on the importance of a smooth implementation, and we appreciate their responsiveness to feedback from our members. The UAD 3.6 significantly improves the appraisal product by ensuring greater consistency and better readability. We will continue working closely with the GSEs, FHFA, and our members in the months ahead to support a successful transition to UAD 3.6.”

Why it matters: The additional flexibility gives lenders and their partners more time to complete testing and implementation while continuing the industry’s transition to UAD 3.6.

Go deeper: Importantly, the November 2, 2026, mandate remains in effect, and GSE sellers must request approval (using these forms: Fannie Mae and Freddie Mac) for additional implementation time from the GSEs and provide information on their timeline for fully transitioning to UAD 3.6.

The exception is designed as a phased transition.

• To incent continued diligence in implementing UAD 3.6, beginning March 1, 2027, UAD 2.6 appraisals submitted under the exception will no longer receive valuation-related representation and warranty relief.
• After May 19, all new appraisal submissions must use UAD 3.6, with UAD 2.6 permitted only for resubmissions through June 27 before the legacy format is fully retired.
• Separately, this week, the Federal Housing Administration (FHA) announced that its Electronic Appraisal Delivery (EAD) portal is now open for optional UAD 3.6 production. FHA-approved lenders may begin submitting UAD 3.6 appraisals immediately or continue using UAD 2.6 for some or all FHA cases. FHA has not yet established a mandatory UAD 3.6 adoption date and will continue assessing lender readiness before doing so.

What’s next: Lenders that need additional time should review the GSE requirements and submit their requests. MBA will continue working with members, the GSEs, FHFA, and FHA to ensure timely and complete implementation of UAD 3.6. 

For more information, please contact Rick Hill at (202) 557-2718 or Darnell Peterson at (202) 557-2922.

GSEs Publish Aligned LLPA Grid for Classic FICO and VantageScore 4.0

Last week, Fannie Mae and Freddie Mac published updates to their selling guides, which revise the loan level pricing adjustments (LLPAs) to be used for VantageScore 4.0.

• These updates followed tweets on Monday from FHFA Director Bill Pulte stating that loans delivered to the GSEs using VantageScore 4.0 would now be subject to the existing Classic FICO pricing grid.

Why it matters: This is a major change from just a few weeks ago, when a separate pricing grid released after VantageScore 4.0 was approved for use by all lenders delivering to the GSEs.

Go deeper: The new LLPAs are effective for loans purchased on or after October 1, 2026. Details on the aligned grids can be found in Freddie Mac Bulletin 2026-K and Fannie Mae Lender Letter LL-2026-06. 

What’s next: MBA will continue to closely monitor and assess the impacts of this rapidly changing GSE policy related to credit scores – including these most recent LLPA updates – and looks forward to our ongoing dialogue with FHFA and the GSEs to establish a credit reporting system that encourages competition by using modernized credit scores from both providers.

• MBA will also continue to urge an end to the mandatory tri-merge requirement, an issue that FHFA director William Pulte has indicated is under review.  

For more information, please contact Sasha Hewlett at (202) 557-2805.


Senate Banking Committee Holds Confirmation Hearing for Matt Jones as FHA Commissioner

On Thursday, the Senate Banking Committee held a confirmation hearing on the nomination of Matt Jones to serve as Assistant Secretary of Housing at the Department of Housing and Urban Development (HUD) and FHA Commissioner.

• Jones currently serves as HUD’s Deputy Assistant Secretary for Single Family Housing, where he oversees FHA’s single-family housing programs. Prior to joining HUD, Jones served as MBA’s Associate Vice President of Government Housing Finance and held key congressional staff roles for both the Senate Banking and Finance Committees, respectively.
• MBA strongly supports Jones’s nomination, sent a support letter to all members of the Banking Committee ahead of yesterday’s hearing, and will continue engaging with individual Senate offices in support of Jones throughout his confirmation process.

Why it matters: FHA plays a critical role in providing access to affordable mortgage credit and supporting both the single-family and multifamily housing markets. If confirmed, Jones would oversee FHA’s single-family, multifamily, and healthcare mortgage insurance programs. MBA looks forward to working with Jones and HUD leadership to modernize and streamline FHA programs, reduce unnecessary regulatory burdens, and lower costs for homebuyers and renters.

What’s next: The Senate Banking Committee is expected to consider Jones’s nomination after returning from recess on November 9.

For more information, please contact George Rogers at (202) 557-2797 or Jeremy Green at (202) 557-2849.

Ginnie Mae Announces Pool Delivery Dataset Version 4.0 Updates

On Thursday, Ginnie Mae issued APM 26-12: Pool Delivery Dataset (PDD) Version 4.0, updating the data specifications used for pool delivery and loan securitization submissions. The updated version incorporates new fields and modifications to existing fields to help Ginnie Mae better enforce pool eligibility and expand disclosures to investors.

Why it matters: The PDD is a core component of Ginnie Mae’s securitization process and defines the data fields issuers must provide when delivering loans into mortgage-backed securities pools. Issuers can (and should) begin testing PDD Version 4.0 in January 2027, with a mandatory compliance date of June 30, 2027.

What’s next: Issuers should work with their vendors to review the Version 4.0 Implementation Guide to identify and implement any needed updates to their systems, vendor requirements, and operational processes to accommodate the revised dataset specifications. MBA will continue to monitor the implementation and assess any operational impacts on members.

For more information, please contact Kaitlin Hildner at (202) 557-2933.

MBA Survey: Regulatory Uncertainty Is Slowing Responsible AI Adoption in Mortgage Banking

A new industry survey of major nonbank lenders and servicers (predominantly IMBs) finds that they are moving carefully and responsibly to adopt artificial intelligence—but regulatory and compliance uncertainty continues to limit broader use.

• Released last week by MBA and the American Association of Residential Mortgage Regulators and conducted by Boston Consulting Group, the survey, The State of AI Among Mortgage Lenders and Servicers, shows an industry putting foundational safeguards in place while seeking clearer and more consistent supervisory expectations.
• The findings reinforce MBA’s advocacy for practical, risk-based approaches that protect consumers without unnecessarily slowing responsible innovation.

Go deeper: The survey shows that IMBs generally trail banks and insurers in AI development and deployment. Current use is concentrated in productivity tools and document-intensive workflows rather than replacing human judgment in high-stakes mortgage decisions.

• Regulatory and compliance uncertainty remains a leading barrier to broader adoption, even as nearly all respondents report foundational controls such as internal AI policies, privacy protections, and human review of AI-supported processes. Taken together, the findings show an industry proceeding deliberately—building safeguards, preserving accountability, and looking for clearer, more consistent rules of the road.

What’s next: MBA will continue working with state regulators and other stakeholders to promote clearer, more consistent approaches to AI oversight and responsible adoption. That work includes ongoing MISMO FRAME efforts to help the industry apply practical risk-management practices and build confidence in the development and use of AI-enabled tools. Importantly, FRAME also aligns closely with the Conference of State Bank Supervisors’ recently released examiner guidance on AI. 

For more information, visit MBA’s State AI Resource Page, or contact William Kooper at (202) 557-2737 or Rick Hill at (202) 557-2718.

MBA Releases Updated IMB Fact Sheet and Policy Spotlight

MBA has published updated versions of its Independent Mortgage Bankers (IMB) Fact Sheet and IMB Policy Spotlight issue briefs.

• Today’s IMB sector continues to play a leading role in serving the single-family mortgage market with sustainable mortgage products through all economic cycles. These two documents offer a clear view of the IMB business model and MBA’s policy framework for IMBs.

Go deeper:

• The IMB Fact Sheet highlights how IMB’s lead the market in serving low- and moderate-income borrowers and the broader mortgage market. The Fact Sheet also outlines for policymakers the extensive regulatory oversight governing IMB operations.
• The IMB Policy Spotlight provides a comprehensive look at MBA’s work on AI issues, including takeaways from a recent IMB industry AI survey, AI myths and facts, MBA’s AI policy framework, and how your IMB can establish robust AI governance based on MISMO’s FRAME initiative.

What’s next: IMBs should use both documents with state and federal policymakers to help inform discussions and navigate the key business challenges facing the industry.

For more information on MBA’s state advocacy and AI policy resources, please visit MBA.org/StateAI or contact William Kooper (wkooper@mba.org).

For more information on MBA’s resources for IMBs, please contact Anthony Siller at (202) 557-2944.

MAA Issues a Call to Action to Oppose Residential PACE Proposal in Massachusetts

Last week, the Mortgage Action Alliance (MAA) and the Massachusetts MBA issued a call to action to urge the removal of a provision from companion bills (H.5576/S.3228), which would authorize residential Property Assessed Clean Energy (R-PACE) financing in the Commonwealth.

• The proposal would permit local governments to establish R-PACE programs that finance residential energy-related improvements through a property-based assessment with super-lien priority over first mortgages.

Why it matters: MBA has long opposed R-PACE because it disrupts the traditional mortgage-lien priority system, creates added risk and complexity for homeowners and lenders, and undermines important consumer protections. R-PACE assessments take priority over an existing mortgage, creating challenges when a homeowner seeks to refinance or sell a property.

• For this reason, the GSEs, FHA, and VA do not permit R-PACE financing on the properties they finance or insure.

Go deeper: A homeowner with an R-PACE assessment may therefore have fewer refinancing options, difficulty accessing a federally backed or conventional mortgage, or delays and complications when selling the home.

• In addition, buyers of homes with PACE liens cannot use GSE, FHA, or VA financing unless the seller agrees to pay off the PACE obligation. R-PACE lending has been subject to well-document fraud and abuse which in 2018 drove Congress to pass MBA-supported legislation requiring the Consumer Financial Protection Bureau to enact strict ability to repay requirements and other consumer protections.

What’s next: MBA and the Massachusetts MBA will continue to collaborate to oppose this legislation. 

For more information on R-PACE, please contact William Kooper (202) 557-2737 or Liz Facemire, CMB, (202) 557-2870, and Jamey Lynch (202) 557-2818 for MAA information.

California Governor Newsom Signs Bill Focusing on Fair Lending Exams, Over Counterproductive CRA Mandates

In a significant advocacy victory for both MBA and the California MBA, California Governor Gavin Newsom signed AB 801.

• Prior to its passage, the bill was substantially amended from its original language which would have established Community Reinvestment Act-style (CRA) requirements for IMBs, credit unions, and state-chartered banks. CMBA and MBA led industry efforts to amend AB 801 to instead focus on establishing a regular examination cycle for fair lending exams already authorized under state law.

Why it matters: The revised bill requires examinations at least once every four years, while also allowing the California Department of Financial Protection and Innovation to accept comparable state or federal exams instead of conducting redundant reviews.

• Language was also added to require the fair lending examination reports to be accorded the same level of confidentiality as all other IMB exam reports in the state.

Go deeper: Last year, after the as-introduced version of AB 801 cleared the state Assembly, the sponsor agreed to pause further consideration to allow for additional discussions regarding the imposition of state community reinvestment requirements to IMBs and others.

• Those conversations, led by MBA, California MBA, and other key industry partners, ultimately resulted in amendments that recast the bill to require the regulator to conduct their fair lending exams on a four-year cycle.

What next: MBA and the California MBA will remain engaged with the legislature and the regulator to focus on policies that promote access to affordable and sustainable mortgages, as well as support DFPI as the examination requirement is implemented. MBA will also continue to oppose any similar CRA-expansion legislation in other states.

For more information, please visit the MBA State CRA resource page, or contact William Kooper (202) 557-2737 or Liz Facemire CMB, at (202) 557- 2870.

Advocacy Takes Center Stage at #MBAAnnual26

MBA’s Annual Convention & Expo, October 11–14 in Chicago, is shaping up to be a powerhouse week for advocacy‑minded attendees — with expanded programming, new MORPAC donor experiences, and multiple ways to plug into the policy conversations shaping our industry.

• Annual26 brings together residential real estate finance professionals, industry leaders, and innovators for engaging speakers, breakout sessions, exhibits, and countless opportunities to exchange ideas and gain actionable insights.

Why it matters: Annual26 is one of the strongest touchpoints of the year for advocates to build their networks, discuss the policy issues affecting the industry, and learn how to deepen their advocacy engagement. Eligible attendees can connect with industry leaders at the Advocacy After Dark: MORPAC Reception on Sunday, October 11 and also by enjoying access to the Liberty Lounge, a dedicated space for connection and conversation throughout the conference.

Additional advocacy programming includes:

• Election Briefing on THE HUB STAGE — Tuesday, October 13, 11:45–12:15 p.m. CT, with insights from MBA’s Legislative & Political Affairs Team on the political landscape and its implications for the industry. Add to your calendar.
• MAA Advocacy Heat Map — Stop by on Monday and Tuesday during the convention to pin your state and help build a nationwide footprint of advocate participation.
• MAA/MORPAC Committee Meeting — Featuring 20+ industry volunteer leaders dedicated to strengthening MBA’s political programs, including MAA, MORPAC, and NAC.

What’s next: Keep the momentum going by registering and attending our next MBA Town Hall, which will include a MAA Post‑Election Special Edition briefing.. Register for the Town Hall.

For more information, please contact Jamey Lynch at (202) 557-2818, Erin Reilly at (202) 557-2751, or Mike Fiegoli at (202) 557-2708.

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:

• Breaking into Non-Agency: A Strategic Playbook for Executive Leadership – October 5
• AI in Residential Lending: The “Agentic” Loan Officer – AI as a Co-Pilot – October 5
• Credit Information Strategies in Today’s Mortgage World – VantageScore – October 6
• How Lenders Can Create More Homes – and Build Their Business – October 6
• Leveraging Assets to Qualify High-Net-Worth Borrowers – October 6
• Credit Information Strategies in Today’s Mortgage World – FICO – October 7
• Credit Information Strategies in Today’s Mortgage World – Factual Data – October 8

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.