Purpose: Address the heightened regulatory environment for the commercial/multifamily real estate industry by representing the interests of members on accounting and regulatory issues before, such agencies as the Securities and Exchange Commission (SEC) and Internal Revenues Service (IRS), as well as standard bodies, such as the Financial Accounting Standards Board (FASB). Offer educational forums on financial disclosure and accounting issues from industry leaders. For more information, contact committee staff liaison Deborah McKinnon at (202) 557-2746 or dmckinnon@mortgagebankers.org .
Current Initiatives: MBA's Accounting, Tax and Financial Analysis Conference
Transfers of Financial Assets (FAS 140) : MBA provides updates to members on the current FASB project to clarify the status of Qualified Special Purpose Entities (QSPE) used in commercial mortgage-backed securities and the extent discretion is permitted in servicing commercial mortgage loans included in a QSPE. FASB expects to issue an exposure draft on potential amendments to FAS 140 by second quarter 2007. MBA will continue to work with relevant associations to educate FASB on any potential amendments to the current accounting treatment for CMBS securitizations.
Implementation of Regulation AB : MBA conducts various educational forums on Regulation AB for servicers and their accountants as well as provided industry feedback to the SEC used as a basis for additional staff interpretive guidance for servicers and their accountants.
Reporting on Internal Control over Financial Reporting : MBA advocates that the SEC and PCAOB should reduce the regulatory uncertainty and high costs of compliance required under Section 404 of the Sarbanes-Oxley Act.
Valuation working group on Mortgage Loans, Loan Commitments and other Hedging Activities (link to FASB website : MBA forms a working group charged with providing industry guidance on the residential and commercial/multifamily real estate industries to FASB.
Reporting Rules for Widely Held Fixed Investment Trusts (WHFIT)
Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable
Industry Resources
Accomplishments:
| 4/30/2007 | MBA and its industry coalition partners submitted a response to the request of the Internal Revenue Service and the Treasury Department (Notice 2007-17) regarding possible amendments to the REMIC regulations for modifications of commercial mortgage loans. Click here to review response. | | 1/29/2007 | MBA and American Securitization Forum (ASF) met with SEC officials to explain the use of vendors in commercial mortgage-backed transactions and how the proposed interpretive guidance requested by MBA and ASF would operate for servicers and their accountants. Click here for memo. | | 1/29/2007 | MBA persuades the Financial Accounting Standards Board (FASB) to revise interpretive guidance for prepayment options embedded in mortgage backed securities. | | 12/21/2006 | MBA and ASF send joint letter on December 21, 2006 to the SEC for clarification on ongoing reporting requirements for vendors under Item 1122 of Regulation AB. | | 12/8/2006 | MBA submits letter to the IRS seeking an exemption for trustees of Ginnie Mae guaranteed securities from reporting under the final reporting WHFIT regulations. | | 12/5/2006 | MBA submits letter to the IRSseeking clarity that mortgage loans will remain treated as an ordinary asset for tax purposes. |
|