MBA Advocacy Update: MBA Responds to CFPB TRID RFI, Supports HUD Manufactured Housing Proposal

MBA Offers Targeted Recommendations to CFPB’s TRID RFI

On Monday, MBA sent a letter (and joined a joint trades letter) to the Consumer Financial Protection Bureau (CFPB or the Bureau) in response to its Request for Information (RFI)  seeking input on reforms to the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) and the combined TILA/RESPA Integrated Disclosure Rule (TRID Rule).

• The RFI is a response to the Promoting Access to Mortgage Credit Executive Order issued by President Trump in March. The RFI seeks comments on 22 questions about potential regulatory changes pertaining to TRID disclosures, TILA rescission rights, and reverse mortgages. It also asks how the current regulations impact smaller lending institutions.

Why it matters: MBA’s letter supports the Bureau’s goal of ensuring that mortgage disclosure requirements provide consumers with the information they need to make informed decisions throughout the origination and settlement process. MBA encouraged the Bureau to prioritize narrow targeted reforms that meaningfully reduce compliance burdens, improve consumer understanding, and expand access to mortgage credit rather than largescale, substantial changes.

Go deeper: MBA suggested several changes to the TRID timing requirements, disclosures, and tolerances, including:

• Adjusting tolerance thresholds for costs that are not within the creditor’s ability to control;
• Allowing a consumer, with informed written consent, to waive or modify waiting periods regardless of whether they are experiencing a bona fide personal emergency;
• Streamlining refinance transactions by eliminating the three-day rescission period;
• Revising the definition of “application” to permit creditors to require additional information before providing the initial Loan Estimate; and,
• Eliminating the TALC table from reverse mortgage disclosures.

What’s next: MBA will keep members informed of any rulemakings that follow the Bureau’s RFI.

For more information, please contact Justin Wiseman at (202) 557- 2854 or Alisha Sears at (202) 557-2390.

Senate Passes Government Funding Extension as September 30th Deadline Looms

Before leaving for August recess, the Senate last weekend overwhelmingly passed a stopgap funding bill (90-6) that would keep the federal government funded through December 11, 2026.

• The Continuing Resolution (CR) largely maintains FY 2026 funding levels across most of the federal government, including at the Department of Housing and Urban Development (HUD), Veterans Affairs (VA), Treasury, and the Department of Agriculture (USDA).
• Importantly, the measure also extends the National Flood Insurance Program (NFIP) through December 11.
• The House previously passed its CR on July 21, which would fund the government only through December 4.

What’s next: The House returns from August recess on August 31, with the Senate following on September 14. That leaves lawmakers just 2½ weeks before the end of the fiscal year to reconcile differences between the two chambers’ varying versions of a CR and reach an agreement on government funding beyond the November midterm elections. MBA continues to urge leaders in both congressional chambers to reach an agreement that avoids a government shutdown on September 30 and provides certainty for the housing and real estate markets.

For more information, please contact Rachel Kelley  at (202) 557-2816, Madisyn Rhone at (202) 557-2741, George Rogers at (202) 557-2797, or Jeremy Green at (202) 557-2849.

MBA Supports HUD Manufactured Housing Modernization Proposal

On Tuesday, MBA submitted a comment letter supporting HUD’s proposed rule to remove the permanent chassis requirement for upper-floor sections of multi-story manufactured homes.

• While the proposal addresses construction standards, MBA supported the change because reducing unnecessary regulatory barriers can expand the availability of affordable manufactured homes that lenders could finance. The proposal also aligns with MBA’s longstanding advocacy to increase sustainable financing and lending opportunities for manufactured housing.

Why it matters:  Modernizing the HUD requirements can reduce unnecessary construction costs, encourage innovation in factory-built housing, and facilitate new manufactured housing designs, including opportunities for infill and higher-density development.

• Importantly, the recently-enacted 21st Century ROAD to Housing Act goes further than this proposal by establishing a framework that can accommodate a broader range of manufactured housing designs, including homes built without a permanent chassis.

What’s next: MBA will remain engaged as HUD implements these broader reforms and will continue to advocate for coordinated financing, appraisal, and secondary-market policies that translate manufacturing modernization into sustainable lending opportunities.

For more information, please contact John McMullen, AMP, at (202) 557-2706.

FHA Updates Single-Family Housing Policy Handbook

On Wednesday, the Federal Housing Administration (FHA) published updates to its Single-Family Housing Policy Handbook.

• Among the most notable changes, FHA added definitions distinguishing written, electronic, and reverification of employment, clarifying the methods lenders may use to document income, particularly when working with third-party verification vendors. FHA also clarified that Federal Home Loan Bank Homeownership Set-Aside Program funds may be provided as either a grant or secondary financing.
• The update also includes several servicing-related revisions. FHA removed the maximum arrearage limitation for Outside the Waterfall loan modifications, clarified that mortgagees should not submit EVARS requests for automatic foreclosure extensions, and added a new appendix identifying the circumstances that qualify for automatic extensions of HUD’s foreclosure initiation timeline.
• FHA also revised the HECM compliance package requirements to include the most recent Life Expectancy Set-Aside analysis and borrower notice.

Why it matters: The update incorporates previously issued Mortgagee Letters, removes outdated guidance, clarifies existing requirements, and makes several technical revisions. Collectively, the changes provide lenders with greater clarity regarding employment verification, affordable housing assistance, loss mitigation, and foreclosure requirements.

What’s next: MBA will continue to review the updates to the FHA Single Family Housing Policy Handbook and report them through the MBA Loan Administration Committee and Residential Loan Production Committee.

For more information, please contact Darnell Peterson at (202) 557-2922 or Gabriel Acosta at (202) 557-2811.

MBA Submits Comments on FHFA’s Proposed Amendment to Suspended Counterparty Rule

Last Wednesday, MBA submitted comments to the Federal Housing Finance Agency (FHFA) in response to its proposed amendment to the Enterprises’ Suspended Counterparty Program (SCP) regulation.

• MBA supports FHFA’s proposal to remove “reputational harm” from the SCP’s assessment criteria. The change would eliminate a redundant and subjective standard, as covered misconduct would still be subject to suspension when it presents a material risk of financial harm or threatens the safety and soundness of the regulated entities. Removing “reputational harm” would therefore preserve FHFA’s ability to address bad actors while ensuring suspension decisions are based on clear, objective, and measurable risks.

Why it matters:  The proposed amendment should achieve FHFA’s goal of ensuring the safety and soundness of Fannie Mae and Freddie Mac (the GSEs) and insulating FHFA-regulated entities from the risks posed by bad actors without unnecessarily penalizing counterparties under an overly broad or ambiguous standard.

What’s next: MBA supports FHFA’s ongoing efforts to improve the SCP rule and will remain engaged with FHFA, the GSEs, and members on this and other critically important housing issues.

For more information, please contact  Sasha Hewlett at (202) 557-2805 or Alisha Sears at (202) 557-2930.

MBA Submits Coalition Letter on FCC’s FNPR to Enhance Know-Your-Upstream-Provider Requirements 

On Monday, MBA and other trades sent a joint letter in response to the Federal Communications Commission’s (FCC) Further Notice of Proposed Rulemaking (FNPR) to enhance “know-your-upstream-provider” (KYUP) requirements and strengthen the “STIR/SHAKEN” caller ID authentication framework.

• Fraud and scams continue to be a pervasive problem that often take an extraordinary financial and emotional toll on consumers. In a December 2025 report, the Federal Trade Commission estimated that in 2024 fraud and scam losses totaled a staggering $196 billion.
• A separate 2026 report found that in 2025, 6% of U.S. adults – an estimated 15.1 million people – say they were scammed out of money. Banks, credit unions, and other financial service providers see firsthand the enormous harm caused by criminals who impersonate trusted financial institutions in illegally “spoofed” calls to consumers and businesses.

The trade groups’ letter urges the FCC to take the following actions:

• Strengthen requirements for A- and B-level STIR/SHAKEN attestations so providers must actually verify that the caller is entitled to use the number being displayed; and,
• Adopt specific KYUP requirements requiring providers to identify, verify, monitor, and take action against upstream providers that facilitate illegal calls.

Why it matters: MBA has previously weighed in on these issues and the letter is consistent with longstanding advocacy on robocalls, spoofing, and fraud prevention. Illegal spoofed calls remain a significant consumer and financial-services problem because some voice providers are assigning A-level and B-level attestations without adequately verifying that callers are authorized to use the telephone numbers displayed on caller ID. The associations argue that inaccurate attestations undermine STIR/SHAKEN by making fraudulent calls appear legitimate.

What’s next: MBA will continue to monitor this proposal and provide any relevant updates.

For more information, please contact Alisha Sears at (202) 557-2390.


MBA Engages with State Regulators at Annual AARMR Conference 

Last week, several MBA staff members joined member company representatives at the annual conference of the American Association of Residential Mortgage Regulators (AARMR) in Bellevue, Wash.

• More than 40 state regulatory agencies made themselves available and provided a series of updates on various NMLS licensing and examination initiatives.

Go deeper: Marina Walsh, CMB, MBA’s Vice President of Industry Analysis, delivered keynote remarks updating state policy makers on the latest MBA forecast, IMB performance, and economic analysis.

• Earlier in the week during the NMLS Ombudsman meeting, staff focused on encouraging regulator engagement with MISMO in developing future iterations of its FRAME AI governance initiative as well as the forthcoming AI FRAME vendor certification.
• Also discussed was MBA’s call for regulators to work with industry to modernize outdated statutes and eliminate redundant requirements, as outlined in MBA’s July letter to the Ombudsman. MBA’s Rick Hill, Vice President of Industry Technology, was invited to a regulator-only meeting to discuss FRAME and the forthcoming MBA-AARMR AI survey, being conducted by Boston Consulting Group.
• MBA State Government Affairs staff also met with the Nevada regulator to discuss MBA’s recent letter on proposed data breach requirements and future State Advocacy Fund efforts to align the state’s monthly reporting with NMLS quarterly Mortgage Call Report submissions and eliminate its physical branch mandate.

What’s next: MBA will continue to engage with all state regulators on AI and NMLS issues, MISMO FRAME, and specifically with the Nevada regulator on legislation that MBA expects to see introduced in 2027.

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


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:

• Introduction to Mandatory Loan Sale Delivery – Aug. 18
• AI Governance, Quality & Risk: A Practical Framework for Mortgage Lenders – Aug. 18
• Using Quality Assurance, Control and Fraud Prevention to Strengthen Loan Operations – August 25
• From Data Chaos to AI-Ready: 3 Use Cases for Loan Documents and How to Implement Them – September 2

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.