Advocacy Update: CFPB Releases RFI on Access to Mortgage Credit

July 13, 2026

Please note: The 21st Century ROAD to Housing Act, which passed the House and Senate in late June, became law on Saturday.

CFPB Releases RFI on Access to Mortgage Credit

On Thursday, the Consumer Financial Protection Bureau (CFPB or Bureau) released an RFI in response to President Trump’s Executive Order (EO) “Promoting Access to Mortgage Credit.”

President Trump’s EO directed the CFPB, the federal banking agencies, and the National Credit Union Administration (NCUA) to pursue regulatory reforms through rulemaking and supervisory guidance aimed at reducing costs and expanding access to mortgage credit. Specifically, the CFPB was instructed to propose changes across several key stages of the mortgage origination process, including updates to major rules under its jurisdiction.
MBA’s summary of the RFI can be found here.

Go deeper: The RFI contains 22 questions and seeks comments about potential regulatory changes pertaining to the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) integrated disclosure requirements (TRID), TILA rescission rights, and reverse mortgages. It also asks how the current regulations impact smaller lending institutions.

On TRID timing and the Right to Rescission, the Bureau, in addition to general questions, asks several questions related to the effects of the timing requirements on consumers’ access to mortgage credit and the cost to creditors, including whether to change the timing requirement.
The Bureau asks whether it should consider changes to the TRID Rule tailored for small banks and credit unions and whether those changes would lower costs for lenders and consumers. Specifically, the Bureau questions whether it should create exemptions or alternative requirements for these institutions.
The Bureau also asks whether to tailor the disclosure requirements in TILA and RESPA to reverse mortgages and if doing so would provide a benefit to consumers, as compared to generic brochures and booklets. Additionally, the Bureau poses whether it should make changes to the Total Annual Loan Cost (TALC) to provide consumers with a more accurate cost estimate of the reverse mortgage.

What’s next: MBA plans to respond to the Bureau and will convene a call with the Legal Issues and Regulatory Compliance Committee to discuss its response by the Aug. 10, 2026, deadline. MBA members interested in sharing their views can participate. Please contact Justin Wiseman at (202) 557- 2854 or Alisha Sears at (202) 557-2390.

Trump Administration Publishes Spring 2026 Regulatory Agenda

Last week, the Trump administration published its Spring 2026 Unified Agenda of Regulatory and Deregulatory Actions, outlining the regulatory actions that federal administrative agencies plan to issue over the next six months.

Why it matters: The rules and proposals published by federal agencies can have significant impacts on lenders and borrowers. The full lists are now available for the Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), the federal banking agencies (FDIC, OCC, and Federal Reserve), the Department of Housing and Urban Development (HUD), the Federal Communications Commission (FCC) and the Federal Trade Commission (FTC).

Go deeper: Notable and/or new activities MBA spotted in the Spring 2026 agenda include:

CFPB

Ability to Repay/Qualified Mortgages – pre-rule stage
Two separate Regulation X rulemakings that the Bureau plans to complete. It also noted plans for a proposed rule on Section 1033 (open banking).
- Additionally, the CFPB has a pre-rule proposal related to Qualified Mortgages and the Ability to Repay rule and, relatedly, a proposed rule on contingencies for calculating Average Prime Offer Rate.
- Importantly and in response to MBA advocacy, the CFPB has included changes to the Loan Originator Compensation Rule in its long-term agenda.

HUD

Proposed revisions to its FHA property flipping rule to eliminate the current 90-day resale restriction and modernize requirements for resales occurring between 90 and 180 days.
The proposal reflects long-standing MBA advocacy to modernize the property flipping rule, improve alignment with broader market practices, and remove unnecessary barriers that can delay home sales and limit affordable homeownership opportunities.

Proposed updates to its minimum property requirements (MPRs) to reduce regulatory burdens, modernize appraisal requirements, and improve the competitiveness of VA-financed home purchases while maintaining protections for Veterans and taxpayers.
The proposal reflects several recommendations MBA has advanced through its advocacy, and MBA will continue engaging with VA to support further modernization of the program.

What’s next: MBA will work with members to monitor and respond to proposals put forth by the government agencies that impact residential, multifamily, and commercial lending activities.

For more information, please contact Justin Wiseman at (202) 557-2854, Alisha Sears at (202) 557-2930, Brendan Kelleher at (202) 557-2779, Sasha Hewlett at (202) 557 -2805, Megan Booth at 202-557-2740, and John Lammle at (202) 557-2789

MBA, Coalition Partners Renew Call for Single-Family Housing Tax Credit

Last week, MBA and a broad group of housing stakeholders urged policymakers to advance a tax/reconciliation package focused on affordability, highlighting the opportunity for Congress and the Trump administration to boost investment in starter homes by pushing for inclusion of the single-family Neighborhood Homes Investment Act (“NHIA,” H.R. 2854/S. 1686) within such a package.

Why it matters: Under the NHIA proposal, federal tax credits would help close the gap between the cost of constructing/rehabilitating a home and its market value. These credits would be allocated by formula to state HFAs and distributed to project sponsors—such as developers, local governments, or financial institutions – who would have five years to complete homes which must be sold at prices generally capped at four times the area’s median family income.

The credit targets “disinvested” urban neighborhoods, rural areas, and communities hit by natural disasters or economic decline. Low- and middle-income families earning up to 140% of area median income (AMI) can purchase homes built with the tax credits, while those earning up to 100% of AMI can access resources to rehabilitate their homes.

Go deeper: Recognizing today’s fiscal environment, NHIA leading sponsors Reps. Mike Kelly (R-PA) and John Larson (D-CT) and Senators Todd Young (R-IN) and Mark Warner (D-VA) have prepared a narrower, four-year version of the NHIA for consideration as a part of any emerging reconciliation framework.

What’s next: House and Senate leaders are working to gauge the feasibility of attempting to craft and move a so-called “Reconciliation 3.0” package prior to the end of the current congressional session. MBA and its coalition partners will continue to advocate for the inclusion of the NHIA proposal in any such package (should it become politically viable).

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 Comments on Proposed NMLS Testing and Education Fee Increases

On Tuesday, MBA sent a letter to the Nationwide Multistate Licensing System (NMLS), the State Regulatory Registry, and the Conference of State Bank Supervisors (CSBS) on its third phase of proposed NMLS fee increases. This last phase would impose small increases in testing and education fees required for licensing under the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act).

Go deeper: Intended to account for growth in operational and technology costs, the proposal increases credit banking fees from $1.50 to $1.55 per hour, effective Jan. 1, 2027, and SAFE Mortgage Loan Originator (MLO) test enrollment increases from $110 to $120, effective March 1, 2027.

Why it matters: In discussion with members, MBA found these increases to be nominal and not substantially impactful to business operations. However, MBA took the opportunity to make four recommendations for the NMLS, based on member feedback, as modernization efforts continue. The letter recommends:

Streamlining the sponsorship submission process to eliminate the need to perform a separate search for sponsorship processing after submitting a filing;
Improving communication on licensing with regulators within the system to be more in line with the State Examination System communication process;
Enhancing MU1 records to allow licensees to designate a Qualified individual (QI) by specific license types within a state; and,
Allowing for designation of team names using a field similar to the “Other Names” or “Prior Names” fields used in individual records.

What’s next: MBA will continue to engage with CSBS as NMLS Modernization rolls out and ask for member feedback on the process.

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 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:

UAD 3.6 Office Hours Part II – July 20
Analyzing the 2025 Mortgage Market: A Deep Dive into New HMDA Data – July 22
The Black Line of Revenue: Building a Pipeline That Holds When the Market Shifts – July 27
How Lenders Can Create More Homes – and Build Their Business – July 28
Expanding Investor Opportunities Through Cash Flow Lending – Aug. 4
Driving Performance in Non-Agency Servicing – Aug. 5
Vetting Closing Agents and Real Estate Attorneys to Mitigate Risk – Aug. 6

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.

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