Advocacy

CREFC Government Relations: Shaping Our Industry

CREFC’s Government Relations team serves as the primary interface between the CRE Finance industry and policymakers. Through a collaborative process with our members, CREFC engages with legislators, regulators, and other policy stakeholders to advocate for policies that promote the interests of our membership and the broader industry.

By joining a CREFC Forum, members are able to participate in the creation of official policy positions and will gain access to regular updates from our Government Relations team on the latest regulatory developments.

View our recent policy wins and sign up for a CREFC Forum below to join our advocacy efforts and make a difference in the direction of our industry. Please contact David McCarthy with any questions.

The First 100 Days

CREFC's Government Relations Team is closely monitoring key legislative and regulatory developments shaping the commercial real estate finance industry. Explore our First 100 Days: Legislative Update and First 100 Days: Regulatory Update for insights into the evolving policy landscape.

  • First 100 Days: Legislative Update (1/28/25)
  • First 100 Days: Regulatory Update (1/28/25)


    • Election 2024 Outcome Analysis: Implications for CRE and Multifamily Finance

    The 2024 election results are in, and CREFC has prepared an in-depth Election 2024 Outcome Analysis to explore how the outcomes will shape policy in 2025 and beyond. This comprehensive analysis examines key issues in the commercial and multifamily real estate finance industry, providing insights into the potential legislative and regulatory landscape.

    While members of CREFC's Government Relations team do not forecast election results, our goal remains to dig deeper into the factors that influence critical areas of legislation and regulation.

    Outcome Analysis:
  • CREFC Election 2024 Outcome Analysis (11/18/24)

    • Scenario Analyses:
  • CREFC Election 2024 Scenario Analysis (10/28/24)
  • CREFC Election 2024 Scenario Analysis (10/22/24)
  • CREFC Election 2024 Scenario Analysis (10/8/24)


    • Recent Policy Developments (as of Q3 2024)
    Basel Endgame Advocacy
    The federal banking regulators plan to repropose the Basel Endgame Capital rules with significant changes. CREFC had submitted comments and coordinated a real estate industry letter on proposed rules and is waiting for the re-proposal to see the extent to which our comments were taken into consideration. CREFC plans to continue advocacy as needed following the release of the re-proposal.

    Tax Policy Working Group
    Convened a group of member experts on tax to analyze and triage key tax priorities ahead of 2025. With the expiration of key provisions in the 2017 Tax Cuts and Jobs Act, Congress is expected to take up a tax bill next year. CREFC will engage with lawmakers and staff on key tax issues through the end in preparation the tax push early next year. 

    15c2-11 No Action Letter Expiration
    CREFC is engaging with CMBS broker dealers on the upcoming application of 15c2-11 public data requirements for conduit CMBS. While CREFC and other trades successfully exempted 144A bonds from the public disclosure requirements, the public CMBS requirements are scheduled to come online in January 2025. CREFC will follow up with the SEC and/or on Capitol Hill as necessary. 

    Conflicts of Interest Rule
    Successfully advocated for narrowing the overly broad scope of the SEC’s Conflicts of Interest in Securitizations rule to target conflicted transactions and relevant parties more appropriately. CREFC partnered with other organization on an implementation toolkit.

     

     

    Latest News

    News

    CREFC's March 2025 Monthly CMBS Loan Performance Report

    April 29, 2025

    CRE Finance Council has released a report on CMBS loan performance for March.* 

    Key takeaways:
      
    DELINQUENCY RATE JUMPS BACK UP


    • Conduit/SASB CMBS combined delinquency of 6.65%
      • Delinquency rate increased 35 bps in March
      • After two consecutive months of decreases totaling 27 bps, the delinquency rate is now at its highest level since February 2021 (6.80%)
      • On a YOY basis, the overall combined delinquency rate is up 198 bps (6.65% vs. 4.67% in March 2024)
    • Multifamily delinquency rate increased 98 bps in March to 5.44%
      • The multifamily rate has now climbed 360 basis points over the past year, from 1.84% to its current level – the highest it has been since December 2015 (8.28%)
    • Office delinquency rate was down slightly (-2 bps) in March, but remains elevated at 9.76% - the highest of all property types
    • March delinquency rate is still 367 bps below the 10.32% peak in June 2020 – the height of pandemic-related lockdowns
    • Loans in special servicing (SS) decreased 21 bps to 10.11% in March; SS has increased in 13 of last 15 months and is up 280 bps YOY 
    *Source: Trepp. CMBS data in this report reflect a total outstanding balance of $643.9B: 54.9% ($353.4B) conduit CMBS, 45.1% ($290.5B) single-asset/single-borrower (SASB) CMBS.
      
    Click here to download the full report. Contact Raj Aidasani for more information on CMBS loan performance. 

    Contact 

    Raj Aidasani
    Managing Director, Research
    646.884.7566

    News Archive

    The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
    CREFC's March 2025 Monthly CMBS Loan Performance Report
    April 30, 2025
    CRE Finance Council has released a report on CMBS loan performance for March.
    More info...

    News

    It’s a Wrap: First 100 Days in Regulatory Changes

    April 29, 2025

    The Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) issued initial implementation guidance on April 17 to bring historically independent agencies into compliance with President Donald Trump’s February Executive Order (EO) “Ensuring Accountability for All Agencies.”

    OIRA notes that it is likely to issue additional guidance as more clarification is needed. The initial guidance clarifies that these independent agencies’ regulatory actions are subject to OIRA’s review:
     
    • The guidance explains that independent regulatory agencies must involve OIRA at all stages of rulemaking (e.g., advanced notices of proposed rulemaking, notices of proposed rulemaking, and final rules) and are subject to this centralized review.
    • It applies to at least 20 boards, commissions and other agencies, including the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Securities and Exchange Commission (SEC).
    • However, it does clarify that the February EO shall apply to the Board of Governors of the Federal Reserve System “only in connection with its conduct and authorities directly related to its supervision and regulation of financial institutions”; i.e., shall not apply to its monetary policy activities.
    To comply with the February EO, each agency is directed to designate employees to fulfill two positions:
     
    • Regulatory Policy Officer (RPO): As a direct report to the agency head, the RPO will be a political appointee with the authority to approve (or obtain the approval of) policy positions on behalf of the agency; and
    • Regulatory Second is a less formal but crucial role played by a senior agency official (traditionally a career employee) who coordinates or leads an office in coordinating agency work on all regulatory actions reviewed under the EO.

    Although the appointments of the above positions were to have taken place by April 21, information has not yet been made public.

    As reported in previous CREFC Policy and Capital Markets Briefings, market watchers have speculated that the Trump administration might be considering consolidating the banking agencies.
     
    • According to the American Banker, however, Treasury Secretary Scott Bessent, who has said that the banking agencies should be “singing in unison from the same song sheet,” might be looking to this detailed guidance as a substitute for agency consolidation.
    New Regulatory Leadership Developments: On April 21, Paul Atkins was sworn in as the new SEC Chair. Other leadership confirmations remain outstanding. Please see here for CREFC’s Regulatory Tracker.

    Contact Sairah Burki (sburki@crefc.org) with any questions.

    Contact 

    Sairah Burki
    Managing Director,
    Head of Regulatory Affairs and Sustainability
    703.201.4294
    sburki@crefc.org

    News Archive

    The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
    It’s a Wrap: First 100 Days in Regulatory Changes
    April 29, 2025
    The Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) issued initial implementation guidance on April 17.
    More info...

    News

    Committee Calendar for the Week

    April 29, 2025

    Key congressional financial services committees will hold several hearings this week and a markup of legislation related to the reconciliation bill. 

    • The House Financial Services Committee bill slated for markup is fairly narrow and primarily looks to reduce funding levels for the Consumer Financial Protection Bureau (CFPB). 
    •  The Senate Banking Committee will hold a hearing on insurance and mitigation procedures.

    Tuesday, April 29

    • House Financial Services will hold a hearing titled Regulatory Overreach: The Price Tag on American Prosperity at 10:00 AM.
    • House Financial Services will hold a hearing titled Exposing the Proxy Advisory Cartel: How ISS & Glass Lewis Influence Markets at 2:00 PM.

    Wednesday, April 30

    Thursday, May 1

    • Senate Banking will hold a hearing titled Examining Insurance Markets and the Role of Mitigation Policies at 10:00 AM.
       
    Contact David McCarthy (dmccarthy@crefc.org) with any questions.

    Contact 

    David McCarthy
    Managing Director,
    Chief Lobbyist, Head of Legislative Affairs
    202.448.0855
    dmccarthy@crefc.org

    News Archive

    The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
    Committee Calendar for the Week
    April 29, 2025
    Key congressional financial services committees will hold several hearings this week and a markup of legislation related to the reconciliation bill.
    More info...

    More Advocacy Resources

    CREFC Policy and Capital Markets Briefing

    Read the latest issue of CREFC's weekly Policy and Capital Markets Briefing

    CREFC Policy Tracker

    CREFC’s Policy Tracker includes a variety of visual aids and updates to help members understand, track, and analyze key policy issues affecting the CRE and multifamily finance industry.

    ESG Initiatives

     CREFC’s Sustainability Initiative seeks to align the objectives of our members and the CRE finance industry with the opportunities and challenges of environmental, social and corporate sustainability.
     

    Read the Latest Government Relations Alerts

    For our weekly government relations and industry policy briefings, please visit our Document Resource Center. The Document Resource Center contains CREFC position papers, analyses, testimony, and other policy tools.

    Become a Member

    CREFC offers industry participants an unparalleled ability to connect, participate, advocate and learn!
    Join Now

    Sign Up for eNews

    Subscribe