Advocacy Update: FHA Proposes MPR Updates; MBA Submits Comments on FHA RAP Demonstration; more

FHA Proposes Updates to its Minimum Property Requirements

On Tuesday, the Federal Housing Administration (FHA) published proposed changes to its minimum property requirements (MPR).

• For years, MBA has urged FHA to modernize its property standards by eliminating outdated or unnecessarily prescriptive requirements, providing greater clarity and flexibility, and better aligning FHA policies with those used elsewhere in the mortgage market, particularly by the GSEs. 
• Earlier this year, MBA and a coalition of industry trades submitted recommendations to FHA in response to its MPR request for information, emphasizing that a more consistent, risk-based framework could reduce unnecessary costs, delays, and uncertainty for lenders and borrowers.

Why it matters: MBA applauds these proposed changes, which would represent the first comprehensive update to FHA’s MPRs in 20 years.

What’s next: MBA is reviewing the proposal and will have a member feedback call on Monday, September 28, from 4:00–5:00 pm ET. Members are encouraged to review the draft and share concerns and operational considerations, and recommend revisions. The proposed changes were published on the Single-Family Drafting Table, and FHA is accepting stakeholder feedback through Nov. 6, 2026.

For more information and to participate in the Government Loan Production Subcommittee’s review process, please contact Darnell Peterson at (202) 557-2922.

MBA Submits Feedback on FHA’s Draft RAP Demonstration

Earlier this month submitted feedback on FHA’s Draft Mortgagee Letter establishing the Partial Claim Reinstatement Advance Payment (RAP) Demonstration.

• The RAP would provide FHA servicers with an alternative partial claim structure that reduces operational burden by eliminating the need to obtain and record a subordinate lien. The proposal also addresses challenges associated with nonjudicial foreclosures involving subordinate debt owed to the federal government.

Why it matters: The RAP aligns FHA’s loss mitigation framework more closely with recent servicer advance model partial claim programs implemented by USDA and VA. By streamlining partial claim administration and addressing foreclosure-related complications, the program could reduce servicing costs and operational complexity while maintaining borrower assistance options.

Go deeper: MBA supports the RAP program and urged FHA to make several important changes:

• provide additional guidance on how RAP information will be conveyed during servicing transfers and streamline refinances;
• clarify expectations for foreclosure bid and claims calculations;
• offer greater detail on servicing the RAP Terms of Repayment (RAPTORs); and
• establish filing-deadline penalties that are proportionate to any resulting harm.

MBA also believes that RAP obligations should be excluded from pooled mortgage balances and treated consistently with other agency-authorized partial claim and servicing advance structures for securitization and re-pooling purposes.

What’s next: MBA will continue to engage with FHA as they work to finalize the policy.

For more information, please contact Kaitlin Hildner at (202) 557-2933.

FASB Issues Proposed Accounting Standards Update on Measuring Mortgage Servicing Rights

On Wednesday, the Financial Accounting Standards Board (FASB) issued a proposed accounting standards update (Proposed ASU) intended to clarify the accounting for recapture rights under U.S. Generally Accepted Accounting Principles (“GAAP”). 

• In March 2026, at the urging of an MBA member company, FASB’s Emerging Issues Task Force (EITF) recommended that the Board address whether the value attributable to recapture should be included when measuring a mortgage servicing right (MSR) under the accounting rules. The EITF agreed that current accounting rules do not clearly address this question, which has resulted in diversity in practice.  
• The FASB declined to include a GAAP definition of recapture in the Proposed ASU, but concludes that an MSR and recapture are a single unit of account, and, therefore, the measurement of an MSR should include the effects of recapture.

Why it matters: While clarity on whether recapture should be accounted for as part of an MSR or as a separate intangible asset under GAAP is important—and would eliminate diversity in practice—that clarification should not create unintended consequences for market participants. These could include implications for warehouse lenders and other MSR financiers that lend against “recapture,” as well as counterparties that could face valuation changes resulting from the guidance.

What’s next: MBA is reviewing FASB’s analysis supporting the conclusions in the Proposed ASU and will work with the MBA Accounting & Financial Management Committee to develop its comments and respond by the November 9, 2026, deadline.

For more information, please contact Fran Mordi at (202) 557-2688.

MBA Submits Coalition Letter to FCC’s Proposed Robocall Mitigation Scorecard

On Tuesday, MBA and coalition of trades sent a joint letter to the Federal Communications Commission (FCC) expressing support for its “Robocall Mitigation Scorecard.”

Go deeper: The FCC has proposed establishing a public “Scorecard” to assess voice service providers’ efforts to combat illegal robocalls and spoofing. We commend the FCC for this proposal and its broader efforts to require providers to take meaningful steps to prevent illegally spoofed calls from reaching consumers.

• Fraud and scams remain pervasive, causing significant financial and emotional harm. Financial institutions see firsthand the damage caused by criminals impersonating trusted institutions through illegal spoofed calls.

The groups urged the FCC to: 

• produce a Scorecard that provides quantitative measures of how effectively voice service providers keep illegally spoofed calls off their networks;
• include a Scorecard rating to all voice service providers in the call’s pathway, including originating and intermediate providers, in order to create market pressure for originating and intermediate providers to avoid originating or transiting illegally spoofed calls; and, 
• encourage the FCC to rate wireless providers based on their effectiveness in keeping illegal text messages off their network.

Why it matters: MBA has long advocated for stronger protections against robocalls, spoofing, and fraud. Fraudsters routinely use illegally spoofed calls to impersonate financial institutions, payment providers, government agencies, law enforcement, and other trusted organizations, causing significant harm to consumers. A robust Scorecard could increase transparency into providers’ efforts to prevent illegal calls and give businesses a meaningful tool to assess their robocall mitigation practices.

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’s Liz Facemire Appointed to New State Regulator Advisory Panel

On Board of Managers of the State Regulatory Registry (SRR) this week announced that MBA Associate Vice President of State Government Affairs Liz Facemire, CMB, will serve on the SRR’s new Nonbank Industry Advisory Council (NIAC). Facemire is the staff lead for MBA’s State Legislative and Regulatory Committee (SLRC).

Why it matters: The NIAC was chartered by the SRR Board to advise it and other state system governance bodies on a wide range of topics relevant to Nationwide Multistate Licensing System and Registry (NMLS), State Examination System (SES) and state system of nonbank supervision. The NIAC will operate as a collaborative and iterative forum to bring industry into conversations with regulators early on a wide variety of topics including developing systems and policies related to the state system of nonbank supervision.

What’s next: The NIAC will meet virtually three times during the year and once in person at the NMLS Annual Conference & Training. Facemire will provide regular reporting to the SLRC and coordinate with MBA member company representatives also appointed to the Council.

For more information, please contact 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:

• Breaking into Non-Agency: A Strategic Playbook for Executive Leadership – October 5
• AI in Residential Lending: The “Agentic” Loan Officer – AI as a Co-Pilot – October 5
• Credit Information Strategies in Today’s Mortgage World – VantageScore – October 6
• Credit Information Strategies in Today’s Mortgage World – Factual Data – October 8

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.