MBA Advocacy Update: HUD, GSE ROV Implementation Date Extended; MBA Pushes CFPB on Repeat Offenders Registry; Rural Housing Legislation Introduced
HUD, GSEs Address MBA Concerns; Extend ROV Policy Implementation Date
On Tuesday, the Federal Housing Finance Agency (FHA) and Fannie Mae and Freddie Mac responded to MBA-raised concerns by announcing that they will delay the implementation date for their new Reconsideration of Value (ROV) policy.
Originally scheduled for August 29 and September 2, respectively, the new implementation date is now October 31, 2024, providing lenders an additional 60 days.
Why it matters: Last month, MBA sent a letter to the Federal Housing Finance Agency (FHFA) and the Department of Housing and Urban Development (HUD) asking for a delay in implementing their expanded Reconsideration of Value (ROV) policies, which were each announced in May 2024.
The new policies require lenders to establish an ROV process for borrowers to dispute appraisal valuations and provide them with a comprehensive disclosure outlining the ROV procedure at the loan application stage, among other changes.
The bottom line: MBA recognizes the value of ROV policies as a helpful tool in ensuring fairness, transparency, and accuracy in property valuations. The extension will allow lenders and their vendors to ensure that all necessary measures are in place to comply with the new standards, enabling the industry to better support the objectives of HUD and FHFA.
For more information, please contact Darnell Peterson at (202) 557-2922.
AARMR Conference Recap: MBA Pushes CFPB to Release Written Guidance to Implement its Registry to Detect Corporate Repeat Offenders
Last week MBA staff attended the annual American Association of Residential Mortgage Regulators (AARMR) Conference, which this year featured 120 state mortgage regulators from 41 states.
During the Nationwide Multistate Licensing System and Registry (NMLS) Ombudsman meeting, MBA delivered an unambiguous message to staff from the Consumer Financial Protection Bureau (CFPB) that written implementation guidance for its new registry of nonbank enforcement orders is needed immediately.
Go deeper: The final regulation was announced on June 3 with a mid-October start date for some lenders to begin submitting data. The rule included a provision to allow entities on the NMLS to comply by uploading information in the NMLS Consumer Access database, but CFPB has not yet provided any written guidance or process for complying with this costly new mandate. CFPB noted only that compliance tools would be released “soon.”
Compounding the industry’s disappointment was news during the meeting from the Conference of State Bank Supervisors (CSBS) that NMLS Consumer Access will be unable to provide any digital interface from the NMLS to the new CFPB registry, which would have provided a convenient method of uploading data required to take advantage of the rule’s option to provide CFPB with historical NMLS information.
Why it matters: MBA opposed this proposal, as did a broad coalition of state regulators in a separate letter. Both industry and regulators remarked on how www.NMLSConsumerAccess.org already achieves CFPB’s objectives, has functioned effectively for a decade and a half, is included in hundreds of industry advertisements every day, and is free and well known to consumers and all other stakeholders. The CFPB ignored these commonsense arguments in finalizing the rule and has thus far failed to provide any instructions or training in how to implement it.
What’s next: MBA will continue to urge CFPB to deliver compliance instructions and tools as soon as possible and will share any new developments on this issue.
For more information, please contact William Kooper (202) 557-2737 or Liz Facemire (202) 557-2870.
MBA Indicates Support for Rural Housing Legislation Offering USDA Loan Assumability
On Wednesday, Senator Peter Welch (D-VT) announced the introduction of S.4971, the Rural Homeownership Continuity Act of 2024.
MBA supports the legislation, as it provides the opportunity to assume a home seller’s U.S. Department of Agriculture (USDA) Rural Housing Service (RHS) mortgage and aligns the program with other government-backed lending. The text of the legislation can be found here.
Why it matters: MBA has testified previously before the Senate Banking Committee’s Housing, Transportation, and Community Development Subcommittee on the need to update USDA home loan products and improve the capacity of the RHS to work more effectively with participating lenders. If enacted, the Welch legislation would improve affordability, boost home buying and selling activity, and increase lending options – on a prospective basis – for rural communities.
What’s next: MBA will work with lawmakers to build bipartisan support for this legislation in the remaining months of the current congressional session.
For more information, please contact Ethan Saxon at (202) 557-2913 or George Rogers at (202) 557-2797.
MBA Staff Raise Key Housing Issues During National Conference of State Legislators’ Policy Summit
Last week MBA staff attended the National Conference of State Legislator’s (NCSL) Legislative Summit, an event that consistently draws thousands of state legislative leaders and staff from across the country including many from key housing financial services committees.
MBA engaged in sessions on artificial intelligence, housing supply, and the homeowner’s insurance crisis to urge policy makers to work with state and local associations and to take advantage of MBA resources such as industry research and data.
Go deeper: MBA also urged state representatives to move cautiously on any legislation that could produce unintended and detrimental impacts to mortgage origination and servicing, such as fast-moving efforts to regulate the use of artificial intelligence. MBA’s attendance in these sessions not only provided context to the issues within each state, but also demonstrated to legislators that the industry is constructively engaged in their deliberations and available to serve as a resource.
Why it matters: NCSL is essentially a trade association of state legislators who share ideas and develop model legislation for individual states to use as a baseline. Industry engagement is vital at NCSL and meetings of other state policymakers to ensure that MBA member views are represented in any “model bill” process that could directly impact future legislation across the country.
What’s next: MBA will follow up with state association partners to support their advocacy.
For more information, please contact Liz Facemire (202) 557-2870.
Participate in the MAA Advocacy in August Campaign!
MBA’s “Advocacy in August” campaign is well underway! Join your fellow industry advocates and MAA members and get involved during the congressional August recess by taking action on current real estate finance policy priorities – and by arranging to meet with elected officials back in their home states or districts.
Why it matters: The “Advocacy in August” campaign is an important political engagement strategy for our industry to help advance key policy and advocacy priorities. Your participation allows us to build and strengthen individual relationships with lawmakers during the traditional congressional August recess.
What’s next: MBA’s Legislative and Political Affairs team will help coordinate in-person and virtual meetings in your elected officials’ home states or districts. Get involved!
For more information, please contact Jamey Lynch at 202-557-2818.
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 – which are complimentary to MBA members:
Adding Reverse Mortgages to Your Business Line: Regulatory/Compliance Considerations – August 20
Analyzing the Commercial/Multifamily Borrower’s Balance Sheet and REO Schedule – August 27
Understanding the New FHFA and HUD ROV Policy: Implications and Implementation – August 27
Understanding Consumers, Buyers, and Uses of Accessory Dwelling Units – August 29
Benchmarking & Performance Ratios Mortgage Bankers Must Know – September 5
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 or (202) 557-2931.
