This week the Senate began consideration of a bill to reauthorize the National Flood Insurance Program for five years, a priority for MBA. The Senate also spent time this week debating a farm bill to which senators are attempting to attach an MBA-supported amendment that preserves access to the USDA's rural housing programs. Next week, a key House subcommittee will hold a hearing on RESPA and TILA disclosures at which MBA will testify.

In this Issue:

Mortgage Action Alliance Swings into Action to Support a QM Safe Harbor

This week, members of the Mortgage Action Alliance, Inc. � (MAA) wrote to their members of the U.S. House of Representatives, asking them to sign a bipartisan "Dear Colleague" letter to the Consumer Financial Protection Bureau (CFPB). The letter, a high priority for MBA, urges the CFPB to structure the definition of a qualified mortgage in the pending "ability to repay" rule as a strong legal safe harbor and not as a rebuttable presumption. Citing the CFPB's testimony before Congress, the letter adds that bright line standards are necessary to prevent future litigation. Additionally, MAA urged attendees of this year's National Advocacy Conference, who briefed their representatives in April about this letter, to call Congress this week in order to follow-up on those conversations. The letter, currently being circulated by Congress members Rep. Shelley Moore Capito (R-WV) and Rep. Brad Sherman (D-CA), needs your support NOW. To use the MAA Call to Action to ask your member of the House to support this important correspondence, please click here. For more information, please contact William Kooper, (202) 557-2737.

Industry Developments:

FEMA Updates the Standard Flood Hazard Determination Form 

The Federal Emergency Management Agency (FEMA) and the National Flood Insurance Program have completed the Standard Flood Hazard Determination Form (SFHDF). The SFHDF was developed as a part of the 1994 National Flood Insurance Reform Act to provide a "standard form for determining whether a building or mobile home is located within a identified Special Flood Hazard Area, if flood insurance is required and if flood insurance is available" (60FR 35276). On December 20, 2011, MBA and the National Flood Determination Association (NFDA) submitted a joint comment letter regarding proposed technical changes to the SFHDF, which expired on December 31, 2011. The letter questioned the likelihood that these changes would "improve the quality of the flood determination process or the lenders' ability to comply with regulations". The final form released June 6, 2012, incorporates many of the technical recommendations made in the aforementioned December 20 letter and expires on May 30, 2015. For more information, please contact Vicki Vidal, (202) 557-2861, or Kathy Marquardt, (202) 557-2742.

MBA Comment and Congressional Letter(s): 

MBA Submits Comment Letter to Federal Housing Finance Agency

On Thursday, June 14, 2012, MBA submitted a comment letter in response to the Federal Housing Finance Agency's draft Strategic Plan: Fiscal Years 2013-2017.  The Strategic Plan restates the objectives announced by FHFA earlier this year with respect to the GSEs.  MBA's response emphasized existing policy positions on a wide range of issues, including:

1. Future of the GSEs;
2. Repurchase demands;
3. Servicing compensation and standards;
4. Standardization, including a single security;
5. REO Disposition; and
6. MISMO/MERS.

The letter also offers MBA's expertise as the FHFA undertakes initiatives in the multifamily housing finance arena.  This letter was a group effort by a multidisciplinary team. For more information, please contact Michael Carrier, (202) 557-2870.

MBA Submits Letter Urging Continuation of Rural Housing Service Eligibility

MBA, along with the National Association of Realtors and the National Association of Home Builders, sent a letter  this week to Senate leadership urging support for an amendment to legislation currently on the Senate floor that, if enacted, would ensure that rural communities continue to have access to valuable federal housing programs. The 2010 Census produced a revised definition of a "rural" community that narrowed the breadth of communities eligible for Rural Housing Service (RHS) programs. The amendment, sponsored by Senators Ben Nelson (D-NE) and Mike Johanns (R-NE), would expand the definition of "rural" and grandfather communities currently eligible for RHS coverage for ten years. For more information, please contact Meghan Sullivan, (202) 557-2866.