On November 29, MBA reiterated its strong opposition to use of increased Fannie Mae and Freddie Mac guarantee fees to fund legislation unrelated to housing. MBA sent a letter to House leadership opposing the use of g-fees to fund H.R. 6429, an immigration bill that would provide visas for qualified workers in the fields of science, technology, engineering and mathematics (STEM).
MBA also joined other housing trades in sending a joint letter (please see second half of the above attachment) opposing the increase, while the Mortgage Action Alliance issued a Call to Action urging its members to contact their members of Congress to oppose the increase.
MBA Responds to State-Level G-Fee Pricing
On November 26, MBA submitted a comment letter responding to the announcement by the Federal Housing Finance Agency that it would impose an additional charge on mortgages originated in states where foreclosure costs were substantially above the national average.
This charge, which ranges from 15 to 30 basis points based on the state, is intended to reflect the additional costs incurred by Fannie Mae and Freddie Mac when foreclosure proceedings become necessary in these states. MBA requested additional transparency in the pricing model used to determine the fee to be assessed, and recommended a corresponding incentive for those states with less costly foreclosure regimes.
MBA also highlighted the consumer impact of the charge and thanked FHFA for including flexibility with respect to how the charge is financed. Finally, MBA pointed out that the announcement did not address servicer costs, and that the format of the charge varied slightly from the format of other loan-level price adjustments, which could potentially create confusion as originators incorporate the charge into their business practices.
MBA, State MBAs Call for Adoption of CSBS Uniform State Test for Mortgage Loan Officers
Over the past two weeks, MBA has been working with state MBAs nationwide to urge adoption of the Uniform State Test being developed by the Conference of State Bank Supervisors for the licensing of state-regulated mortgage loan officers.
The UST will streamline the pre-licensing testing requirement for loan officer qualifications for states that choose to implement it. So far, 29 states have signaled their intent to CSBS to adopt; these states will be announcing their plans in January and the UST will consequently be available for implementation by states in April 2013.
In its campaign for further state adoption, MBA is providing draft correspondence to state MBAs to submit to their state mortgage banking regulator, along with a memorandum of support to attach from MBA President and CEO David Stevens. In states without an MBA, a letter has been sent directly from MBA to the state mortgage banking regulator. As of today, state MBAs in California, Florida, Maryland, Massachusetts, Maryland, Michigan, North and South Carolina, Ohio and Texas have expressed their support to MBA for the UST and are contacting their state banking regulators; many more state MBAs have articulated their interest and are beginning the process of joining in the campaign.
If you would like to use MBA’s draft letter for state MBAs to write your own letter of support, please click here.
MBA President and CEO Speaks to the Center for American Progress on FHA
On November 30, MBA President & CEO David Stevens participated in an event at the Center for American Progress, Putting the FHA’s Financial Problems in Perspective.
Following a keynote address from acting FHA Commissioner Carol Galante, Stevens participated in a panel discussion, moderated by Nick Timiraos of the Wall Street Journal, that included Roberto Quercia, director at the University of North Carolina Center for Community Capital; Joseph Tracy, senior advisor to the president at the Federal Reserve Bank of New York; Susan Wachter, professor of financial management at The Wharton School; and Sarah Rosen Wartell, president of The Urban Institute.
MBA Highlights Concerns of Independent Mortgage Bankers at CSBS Policy Committee Fly-In
On November 29, MBA staff met with the 11 members of the Conference of State Bank Supervisors Policy Committee, which included regulators from five states and representatives from state regulatory groups, including the American Association of Residential Mortgage Regulators.
The Policy Committee plays an instrumental role in the development of CSBS actions, which influence state regulatory matters nationwide. The conversation was not only an opportunity to express MBA’s support for the Uniform State Test being developed for mortgage loan officers employed at state-regulated lenders, but it was also a forum for MBA to present several issues of concern beyond the inconsistent regulatory landscape that exists for small and independent mortgage bankers.
Among the issues raised by MBA was the inconsistent application by states of licensing requirements for servicing personal generally, and loan modification staff in particular. MBA also voiced its view that it is inappropriate to expand the use of the National Mortgage Licensing Service to apply to pawn brokers and pay day lenders. MBA will continue to present these and other concerns to state regulators, and to raise these issues in other forums to advocate for small and independent members of MBA.
MBA Updates ALEC Conference on SAFE Act and Loan Officer Licensing
On November 28, MBA staff made a presentation to the American Legislative Exchange Council’s Financial Services Subcommittee on the regulatory impact of Dodd-Frank and the unintended consequences of the Secure and Fair Enforcement for Mortgage Licensing Act with respect to state licensing of mortgage loan officers.
The presentation–which took place at ALEC’s 2012 States and Nation Policy Summit in Washington, D.C. –highlighted the need for certainty in the mortgage markets as well as the need for common standards in regulations and consumer protections amidst the many rulemakings affecting the real estate finance industry. MBA highlighted the need for states to consider the totality of the regulatory environment being faced by small and independent mortgage bankers before legislating new requirements and burdens.
With respect to the need for common standards in loan officer licensing, MBA called on Subcommittee members to urge their states’ banking regulators to adopt the Uniform State Test for mortgage loan officers being developed by the Conference of State Bank Supervisors.
