MBA Advocacy Update: VP Harris Unveils Economic agenda; CFPB, FHFA, others Release Data Standards Proposal; MAA Advocacy in August Underway
Vice President Harris Unveils New Economic Agenda
As MBA leaders head to Chicago to take part in Democratic National Convention activities, housing policy – both single and multifamily – remains a robust part of the 2024 election dialogue, with Democratic nominee Vice President Kamala Harris announcing new portions of her proposed economic agenda. Not surprisingly, many of her housing-related proposals build on current Biden administration policies, require additional detail to be fully evaluated (both the pros and the cons), and would need congressional action to be implemented.
What’s next: MBA staff will continue to closely monitor policy proposals that impact real estate finance from both the Trump and Harris campaigns – and will provide you with more granular detail on the key points in the coming days and weeks prior to the November 5th election.
For more information, please contact Bill Killmer at (202) 557-2736 or Pete Mills at (202) 557-2878.
CFPB, FHFA & Federal Banking Agencies Release Proposed Joint Rule on Data Standards
On Tuesday, the Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), the Federal Banking Agencies, and four other federal agencies issued a proposed rule to establish data standards across these agencies. The agencies proposed the rule as required by the Financial Data Transparency Act of 2022.
Why it matters: Although the proposed rule initially creates standards and does not create new reporting requirements, the individual agencies will adopt these standards within their reporting requirements over time. The revised reporting requirements will impact industry participants.
What’s next: MBA will review the proposed rule and provide comments.
For more information, please contact Rick Hill at (202) 557-2718.
USDA Releases Final Rule on Special Servicing Options and the Mortgage Recovery Advance
On Thursday, the U.S. Department of Agriculture (USDA) published a final rule that makes changes to both the special servicing options for non-performing loans and the Mortgage Recovery Advance (MRA) process.
In the final rule, USDA created a single loss mitigation waterfall by requiring that servicers exhaust traditional servicing options before a borrower can be evaluated for special servicing options. USDA also incorporated the MRA as a traditional servicing option and made the process less cumbersome by eliminating documentation and eligibility challenges for borrowers who do not require payment reduction.
Why it matters: USDA believes that these changes will benefit borrowers by offering a less cumbersome option to eliminate documentation and eligibility challenges for borrowers who do not require payment reduction, while providing lenders more flexibility in their servicing options and reducing program risk.
What’s next: This rule has an effective date of February 11, 2025. MBA will keep members informed of any updates.
For more information, please contact Brendan Kelleher at (202) 557-2557.
FHA Releases Draft ML on Modernizing Engagement with Borrowers
On Wednesday, the Federal Housing Administration (FHA) posted a draft Mortgagee Letter (ML), Modernization of Engagement with Borrowers in Default, on its Single Family Housing Drafting Table for feedback. This ML implements the Final Rule, which was released on August 2. The final rule requires that mortgagees make a reasonable effort to meet with the mortgagor using acceptable methods of communication.
Why it matters: MBA previously responded to a similar proposal to eliminate face-to-face requirements. That letter is available here.
In the letter, MBA suggested that FHA should change their proposed language to make it clear that no in-person is required. Additionally, FHA should also allow servicers to contact borrowers over the phone or virtually. Lastly, meeting FHA’s early intervention requirements and discussing loss mitigation options with borrowers should fulfill borrower contact requirements. Many of the changes in the latest draft ML are responsive to MBA’s recommendations.
Go deeper: Under the ML, acceptable methods of communication include telephones, Voice over Internet Protocols (VoIP), interactive virtual communication methods, email, secure web portals, or previously used methods of communications. Servicers must make at least two attempts to contact the borrower. Under the ML, these two contact attempts must be made using two different methods that provide a date or timestamp of delivery and provide the borrower with information about contacting the servicer. Telephone calls that do not result in direct contact with the Borrower do not meet this requirement
What’s next: FHA is accepting feedback through September 13, 2024. MBA will keep members informed of any updates.
For more information, please contact Brendan Kelleher at (202) 557-2557.
Calling All Lenders: Join MISMO’s Inaugural Lender Forum on August 27
On August 27, MISMO is hosting its inaugural Lender Forum. The gathering is an opportunity for lenders of all sizes to come together to discuss challenges specific to business, operational, and implementation issues facing our industry.
The first meeting will be facilitated by Eric Armstrong of Mr. Cooper, Kevin Bowen of Chase, and Suzanne Garwood of Chase. Attendance is complimentary, and discounts to attend the remainder of the MISMO Fall Summit are available.
Why it matters: This new series—for lenders only– will provide a regular platform for collaboration on specific issues that can be solved through the adoption and implementation of industry standards.
What’s next: The first meeting will be held on August 27 at 1:30 PM ET and online via Zoom. Topics of conversation over the coming months will include navigating the current regulatory environment, use of emerging technologies, including artificial intelligence (AI), and how to manage associated risks, requirements associated with FHFA’s imminent credit score changes, and much more.
For more information, and to register please contact info@MISMO.org.
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.
Register for MAA’s Next Quarterly Webinar on September 17
MBA’s Legislative and Political Affairs Team is inviting you to our upcoming Pre-Election Update on National Voter Registration Day, September 17, at 3:00 PM ET. Join us as we dive into the policy implications that could flow from the upcoming 2024 elections and impact our industry.
Why it matters: This webinar will offer a comprehensive overview of the current legislative landscape and forecast potential political changes that could impact your business and the broader industry.
What’s next: Register with code MAA2024 to receive complimentary access to this webinar.
For more information, please contact Erin Reilly at (202) 557-2751 or Margie Ehrhardt 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 – 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.
