Advocacy Update: FHA Actuarial Report Released; Judge Rules CFPB’s Funding Cannot Lapse; More
FHA Actuarial Report Shows Strong Performance
On Wednesday, the Department of Housing and Urban Development (HUD) released its Annual Report to Congress on the financial status of the Federal Housing Administration’s (FHA) Mutual Mortgage Insurance Fund (MMI Fund). The report announced a strong combined capital ratio of 11.47% – unchanged from 2024 and well above the statutory minimum of 2.0%.
• MBA’s summary of FHA’s report can be found here.
• The “MMI Fund Capital” (formerly referred to as “economic net worth”) of the MMIF is $188.87 billion, an increase of $16.7 billion from a year ago. The Forward capital ratio increased to 10.95% in FY25 from 10.88% in FY24; the HECM ratio decreased slightly to 24.06% in FY25 from 24.50% in FY24. The total insurance-in-force reached approximately $1.65 trillion, which is an increase from $1.506 trillion in FY24.
What they’re saying: MBA’s President and CEO Bob Broeksmit, CMB, in a press statement said, “With the Mutual Mortgage Insurance Fund holding a very high capital reserve of 11.47%—well above the 2% statutory minimum—we will review the report in greater detail to assess whether any policy changes are warranted to improve affordability and access to homeownership in 2026, including a potential reduction in FHA’s annual mortgage insurance premiums. Any such changes should be calibrated responsibly and informed by a careful evaluation of the program guidelines and the economic factors behind the rising serious delinquency rate to ensure the program remains safe, sound, and sustainable.”
Why it matters: A healthy FHA program is necessary to ensure the broad availability of sustainable mortgage credit to low- and moderate-income households, minority borrowers, first-time homebuyers, and other historically underserved communities.
• The strength of this year’s annual assessment of the health of the MMI Fund provides an opportunity for HUD to consider further changes to the level and structure of FHA premiums to reduce costs to borrowers while maintaining a healthy buffer above the minimum reserve ratio.
What’s next: MBA will work with HUD – and the Trump administration – as they evaluate any potential changes to FHA pricing and will continue to advocate for other program updates that improve affordability.
For more information, please contact Darnell Peterson at (202) 557-2922.
Judge Rules CFPB’s Funding Cannot Lapse; Hearing Set for February 24
On Tuesday, D.C. District Court Judge Amy Berman Jackson ruled that the Trump administration must continue to seek funding for the Consumer Financial Protection Bureau (CFPB or the Bureau) through February 24, which is when the federal appeals court will hold an en banc hearing. The ruling rejects the Department of Justice’s Office of Legal Counsel (OLC) argument that the CFPB may not legally request funds from the Federal Reserve when the central bank operates at a loss.
• The OLC reached this conclusion based on the fact that the Federal Reserve System currently lacks any “combined earnings” from which the CFPB can draw funding, as required by the Dodd-Frank Act. OLC interprets “combined earnings” to mean profits (revenues minus interest expense), not gross revenues. Given that the Federal Reserve has reported net losses, the OLC concluded that there are no funds from which to draw.
• However, Judge Berman Jackson’s ruling rejected the OLC analysis and compels the CFPB to continue requesting funding from the Federal Reserve’s total net income, even in instances where the central bank’s income is in the red.
• Judge Berman Jackson noted: “The statutory text of the Dodd Frank Act … prescribes a process through which the CFPB is to request the funding it needs to carry out the mission it was assigned by Congress, and the Federal Reserve must provide that funding from its ‘combined earnings’…This process has unfolded seamlessly since the Bureau was established in 2011, even in the years since 2022 when the Federal Reserve’s interest expenses have exceeded its earnings.”
Go deeper: Additionally, a coalition of 21 states along with the District of Columbia sued the Trump administration to prevent it from defunding the CFPB.
• MBA has also consistently noted the importance of maintaining sufficient CFPB funding to ensure the agency has the resources to conduct its statutory duties, including the rulemaking staff needed to propose and finalize reforms to a number of outdated and overreaching mortgage regulations such as the Loan Officer Compensation rule, Reg X servicing rules, and RESPA.
What’s next: In the near term, given prior discussions with the CFPB, MBA expects that the Bureau will continue to publish the weekly Average Prime Offering Rate (APOR) through at least February 24.
• The CFPB announced that the filing period for the Home Mortgage Disclosure Act (HMDA) data collected in 2025 began on January 1, 2026.
MBA will keep members informed about any updates and will continue to be engaged in any relevant rulemakings from the CFPB.
For more information, please contact Justin Wiseman at (202) 557- 2854 or Alisha Sears at (202) 557-2390.
Registration Discount for MBA’s Servicing Solutions Conference Ends January 6
On MBA members save $200 when they register by Tuesday, January 6 for MBA’s Servicing Solutions Conference and Expo, taking place February 16-19 at the Gaylord Texan in Dallas.
Why it matters: This conference is the industry’s premier event tailored to the interests of servicing professionals, with curated content, networking opportunities, and an expo hall featuring solutions providers. Registration rates increase after January 6th.
What’s next: Registered attendees will receive a personalized link to reserve their room at the Gaylord Texan at a discounted rate until January 16. Availability is limited.
For more information, please contact Meetings@mba.org.
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:
• The High-Performance Manager: Proven Systems to Lead, Recruit, & Coach Winning Sales Teams – Jan. 20
• Decoding Customer Satisfaction and Loyalty: Key Insights from J.D. Power’s Latest Mortgage Studies – Jan. 21
• 1099 vs. W-2: Avoiding Costly Compliance Mistakes – Jan. 22
• Marketing Mastery for Loan Originators: Building a Consistent, High-Quality Pipeline – February 9
• Renovation Lending Today: Market Trends, Best Practices & 203(k) Insights – February 12
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.
