MBA Advocacy Update: MBA Urges HUD to Make Appraisal and HECM Changes

1. MBA Urges HUD to Make Appraisal and HECM Changes

On Friday, MBA submitted comments in response to a Department of Housing and Urban Development (HUD) Request for Information (RFI) on how the agency can make its programs easier to access and use. MBA encouraged HUD to release its loan-level appraisal datasets to the GSEs and other federal agencies, as well as to explore alternatives to its current requirement to require a second appraisal on certain Home Equity Conversion Mortgage (HECM) loans. 

• Why it matters: Aggregating appraisal datasets across agencies and investors can improve the precision of AVM models. The second appraisal quality control requirement within the HECM program increases reverse mortgage transaction costs when less-burdensome or costly alternatives can achieve the same goal.
• What’s next: MBA will continue to engage with HUD on opportunities to reduce transaction friction and minimize costs for Federal Housing Administration (FHA) homebuyers.

For more information, please contact Matt Jones at (202) 557-2933.

2. MBA Responds to FHFA’s Request for Information on GSE Pricing

On Monday, MBA submitted comments to the Federal Housing Finance Agency (FHFA) in response to its RFI on Fannie Mae and Freddie Mac’s (the GSEs) single-family pricing framework. The letter highlights MBA’s longstanding advocacy for utility style returns for the GSEs while ensuring a level playing field and allowing for flexibility within that rate of return for different products. MBA also recommended regular reviews of the GSEs’ pricing framework and enhanced engagement with industry to determine appropriate implementation timelines and to avoid potential operational or implementation issues. Finally, MBA noted that the Enterprise Regulatory Capital Framework (ERCF) in its current state is not an accurate reflection of the GSEs risk for a variety of reasons and can be problematic when directly used to making pricing decisions. Instead, GSEs should be granted flexibility to use methods other than pricing to manage certain risks, and in the longer term, MBA recommended FHFA consider further revisions to the ERCF to improve effectiveness and transparency.

• Why it matters: Following public response to recent pricing changes, FHFA hopes this RFI will help provide additional transparency and clarity regarding the GSEs pricing. MBA’s recommendations to FHFA and the Enterprises are intended to improve elements of the pricing framework related to return on capital, implementation, and calibration to the ERCF.
• What’s next: It is unclear how FHFA intends to use the recommendations in the RFI. However, one likely outcome will be a more regular cycle of pricing reviews. MBA will work closely with FHFA on such reviews and any other related matters that arise from this RFI.

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

3. CSBS Responds to MBA’s Letter on NMLS Mortgage Call Report (MCR) Version 6 Announcement

Last Friday, the Conference of State Bank Supervisors (CSBS) responded to concerns MBA raised about planned revisions to the NMLS Mortgage Call Report–the so called- “MCR Version 6” implementation. CSBS acknowledged MBA’s concerns about the burdens on lenders and vendors of an April 2024 compliance requirement. The goal of the MCR Version 6 is to simplify the filing forms for mortgage licensees by moving away from separate forms like “Standard” or “Expanded” to a filing system based on activities (e.g. origination, servicing, brokering). MBA’s suggestions were viewed as constructive – CSBS has agreed to work on comparison tools to highlight the changes between MCR versions and understands the importance of providing the technical specifications so the industry may begin to work on this new form. While the letter does not provide specific changes to the roll out plan, CSBS confirmed they are elevating to their members the timing issues MBA raised and may reconsider the proposed effective date.

• Why it matters: Implementation of changes like the MCR filing require time and affected parties should have ample opportunity to provide feedback. Delaying implementation would allow institutions and vendors to make the appropriate updates to their processes before implementation. Coordination and continued discussions with CSBS provide opportunities to ensure both regulators and industry are aligned on goals such as updates to the MCR.
• What’s next: MBA will continue to work with CSBS on alignment with other forms filings like the Mortgage Bankers Financial Reporting Form (MBFRF) and plans to continue conversations with CSBS.

For more information, please contact William Kooper (202) 557-2737 or Liz Facemire (202) 557-2816.

4. [VIDEO]: On Combating Self-Limiting Behaviors with EscrowTab’s Amy Moses

In this mPower Moments episode, mPower Founder Marcia M. Davies sits down with Amy Moses, Vice President of Marketing and Communications at EscrowTab. Moses discusses her career journey and the lessons she learned while working in the mortgage industry. She shares advice on the importance of stepping outside of one’s comfort zone to get to the next level and the importance of being proactive in the workplace to gain more skills. Moses also offers tips on how the next generation of women mortgage professionals can succeed in the industry. 

• What’s next: To watch more mPower Moments, click here.

For more information, please contact Marcia Davies at (202) 557-2707. 

5. Get Involved–MBA Advocacy Month Kicks Off in September 

Join MBA’s Legislative and Political Affairs (LPA) team in September for MBA Advocacy Month, an all-member campaign focused on raising awareness on the top single-family and commercial/multifamily issues that can help produce positive policy changes at the national level. 

• Why it matters: Throughout September, MBA will work with members to engage with their employees and help run impactful Mortgage Action Alliance (MAA) and MORPAC campaigns. In addition, MBA staff will host virtual events, including legislative townhalls and webinars with a focus on how members can make their voices more effectively and better heard.
• What’s next: If interested in learning more and how to get involved, visit

For more information, please contact Jamey Lynch, AMP at (202) 557-2818.

6. Upcoming MBA Education Webinars on Critical Industry Issues

MBA Education continues to deliver timely programming that covers the spectrum of challenges, obstacles and solutions pertaining to our industry. Below, please see a list of upcoming webinars–which are complimentary to MBA members:

• C-PACE Financing 101: A Commercial/Multifamily Lender’s Overview – August 23
• Current Expected Credit Losses (CECL) Updates – August 24
• Navigating the Obstacles in Multifamily Housing: Perspectives from the Affordable Rental Housing Advisory Council – August 29
• Succeeding Today and Tomorrow: Tech Tools That Can Drive More Market Share – September 7
• Budgeting and Financial Planning for Non-Believers – September 13
• Section 1071: A Practical Approach to Unpacking the CFPB’s Final Rule – September 13

MBA members can register for any of the above events and view recent webinar recordings.

For more information, please contact David Upbin at (202) 557-2931.