MBA Advocacy Update: Senate Letter to Regulators on Basel III; MBA Letter on FHA/Ginnie Mae Funding

Senators Urge Bank Regulators to Modify Basel III Mortgage Provisions

Seven Republican members of the Senate Banking Committee sent a letter to the Federal Reserve and the Office of the Comptroller of the Currency (OCC) regarding the current Basel III bank capital proposal’s impact on the mortgage market. The Senators said the regulators’ proposal to increase mortgage loan capital requirements is significantly more punitive than the proposals adopted in the United Kingdom and urged those policymakers to revisit their proposal.

Why it matters: The Senators’ letter continues the drumbeat of criticism against the proposed Basel III “endgame” rule.

MBA strongly opposes certain provisions that would undermine mortgage credit availability and has explained to policymakers and the media how the proposed rule could affect the macroeconomy and single-family housing and commercial real estate finance markets.

What’s next: MBA is working with members, other industry stakeholders, and elected officials from both sides of the political aisle to formulate a collective response to the proposal, with a focus on outlining the numerous negative impacts it would have on the housing finance ecosystem. Comments are due by January 16, 2024.

For more information, please contact George Rogers at (202) 557-2797 or Ethan Saxon at (202) 557-2913.

MBA Leads Letter to Hill Calling on Funding for FHA and Ginnie Mae

MBA recently led a housing industry coalition letter that urged key House and Senate appropriators to ensure adequate funding for the Federal Housing Administration (FHA) and Ginnie Mae administrative accounts within any emerging Fiscal Year (FY) 2024 budget and spending package.

The letter cautions against the programmatic and consumer harm that would result from a potential 1 percent “across the board” spending cut – as mandated under certain conditions by the Fiscal Responsibility Act debt limit deal earlier this year – if applied to FHA and Ginnie Mae.

Why it matters: Congressional leaders must finalize a spending package for affected federal agencies – including the Department of Housing and Urban Development (HUD) – prior to mid-January 2024 and the expiration of the “first-rung” of a “two-step” Continuing Resolution (CR) signed into law by President Biden in November. The letter specifies the programmatic impacts that would result from inadequate FY2024 funding for these two key HUD subagencies and their operating accounts.

What’s next: MBA and its coalition partners will continue to monitor negotiations and advocate for adequate federal funding at HUD that gives FHA and Ginnie Mae the resources needed to fulfill their respective missions.

For more information, please contact Rachel Kelley at (202) 302-1185, Ethan Saxon at (202) 557-2913, George Rogers at (202) 557-2797, or Bill Killmer at (202) 557-2936.

Mortgage Call Report Version 6 Implementation Update

The Conference of State Bank Supervisors (CSBS) reecently hosted its final biweekly “Office Hours” on MCRV6 implementation in 2023.

Staff noted that the filing test environment will open in January, and licensees will receive an email with information to participate. MBA urges members to participate in this testing phase to ensure all issues are addressed prior to the April 2024 filing date.

Go deeper: CSBS announced they will release updates to their FAQ document, including a list of states who have agreed to use the State Specific Supplemental Form (SSSF) and an updated list states offering a grace period for Q1 2024 MCRV6 filings. All updates will be provided on the MCRV6 Resource page. Office Hours will resume every other Monday starting January 15th at 1:00 PM EST. To join the Zoom meetings, use the following link and ID and Passcode:


Meeting ID: 821 0299 5323

Passcode: 102696

Why it matters: Licensees must be prepared to start collecting the appropriate MCR data beginning in 2024.

What’s next: MBA and its state partners are reaching out to state regulators to urge them to offer licensees a grace period or other flexibilities for Q1 2024 MCR filings.

For more information, please contact William Kooper (202) 557-2737 or Liz Facemire (202) 557-2870.

Upcoming MBA Education Webinars on Critical Industry Issues

MBA Education continues to deliver timely single-family and commercial/multifamily 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:

C-PACE for New Development, Refinance, Renovation, and Rescue – Jan. 30

Transforming Lending Operations: How to Leverage Intelligent Automation – Jan. 30

Builder’s Risk Insurance: Analysis & Perspectives – March 20

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.