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.

View CREFC's Advocacy resources below, and get involved today!

CREFC PAC

Strengthening Your Voice in Washington, D.C.

CRE Finance Council is dedicated to promoting the ongoing strength, liquidity and viability of the commercial real estate finance markets. To that end, CRE Finance Council’s Washington political outreach program aims to improve the statutory and regulatory regimes governing our members’ business. CRE Finance Council PAC is an essential adjunct to CREFC's lobbying efforts, allowing us to build relationships and have our voice to be heard at all levels of debate on issues of concern to the CRE finance industry.

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Resource Center

ELECTIONS

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)

Elections

Get Involved

CREFC members who would like to engage actively in advocacy are encouraged to join one or both of the following committees, which help CREFC respond to evolving legal, legislative, and policy developments:

Advocacy Committee
Legal Advisory Committee

The Advocacy Committee, open to all CREFC members, complements CREFC’s existing Policy Committee by broadening participation in discussions around legislative and regulatory developments. It provides an avenue for more members, both Forum leadership and other industry stakeholders, to weigh in on critical policy issues.

The Legal Advisory Committee brings together both internal and external counsel from CREFC’s diverse membership base. It serves as a sounding board to quickly evaluate proposed regulatory changes and help determine those issues most important to CREFC and its members. This committee is open to CREFC attorney members (e.g., law firms, internal counsel).

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 to join our advocacy efforts and make a difference in the direction of our industry. Please contact Sairah Burki or David McCarthy with any questions.

Get Involved

PCM

Policy and Capital Markets Briefing

CREFC’s Policy and Capital Markets Briefing provides CREFC members with insights and analyses on events impacting the industry.

Recent Headlines from our Sept. 16th, 2025 issue

CREFC Participates in Treasury Roundtables on GSE Reform
Section 899 Again? Officials Float Return of “Revenge Tax”
FSOC Public Session Highlights Bank Regulatory Priorities
Confirmed: Fed Nomination Fast Tracked
Senate Deposit Insurance Hearing
CREFC Enhances CRE CLO Transparency with New Investor Reporting Standards
Government Funding Update
Economy, the Fed, and Rates…

If you are a member, click the Resource Center Button to see the PCM.

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PCM Stories Samples

Policy and Capital Markets Briefing

CREFC POLICY TRACKERS

CREFC Policy Trackers

CREFC’s Government Relations team develops a variety of visual aids and trackers to help members understand, track, and analyze key policy issues affecting the CRE and multifamily finance industry.

Please contact David McCarthy with questions on any of the materials or to suggest additional visual resources.

Election Scenario Analysis: PCM report

Election 2024 Scenario Analysis (Updated 10.28.24)

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.

CREFC Policy Trackers

Risk & Resilience Committee

Introducing CREFC’s Property Risk & Resilience Committee

(Formerly the Sustainability Initiative)

CREFC is excited to announce the rebranding of the Sustainability Initiative to the Property Risk & Resilience Committee, a change that better reflects our members’ evolving priorities and mission.

Launched in 2021, our initiative focused on the roles that climate risk and sustainability efforts play in the long-term health of the commercial real estate finance market. As climate-related risks grow in both frequency and severity, so too does the need for a deeper understanding of how these forces impact property performance, asset valuation, and overall market stability.

The new name, Property Risk & Resilience Committee, more accurately captures our expanded focus:

Risk: Helping investors, lenders, and other CRE finance stakeholders understand the physical and financial risks posed by extreme weather events and long-term climate trends.
Resilience: Promoting strategies that strengthen the built environment, through energy efficiency, emissions reduction, and smart infrastructure investment, to ensure properties remain desirable and viable over time.

What We Do

The Committee serves as both an educational resource and advocate for the commercial real estate finance industry, providing insight into how macro-level environmental and regulatory trends intersect with financing decisions.

Our work includes:

Surveys & Research: The Committee has conducted in-depth surveys of our members to better understand market attitudes and practices around sustainability, risk management, and regulatory preparedness.
Strategic Issues Monitor (SIM): In partnership with Oxford Analytica, the Committee produces a biannual benchmark tool that helps CRE-related organizations identify, assess, and track the macro trends most likely to affect U.S. commercial real estate and the CRE finance market over the next three years.
Webinars & Panels: The Committee has hosted dozens of educational sessions for CREFC members, covering a wide range of topics, from energy efficiency standards and emissions targets to insurance challenges and climate risk disclosure frameworks .

Why This Matters

CRE lenders and investors are looking not only for solid market returns, but also for resilient, forward-looking assets. Properties that lag behind on emissions performance or climate adaptation are increasingly at risk of becoming “stranded” or undesirable in the market.

By equipping the CRE finance community with the relevant tools, data, and insights, the Property Risk & Resilience Committee supports better investment decisions and a more resilient built environment.

CREFC's Property Risk and Resilience Committee

CREFC Advocacy Staff

Sairah Burki

Managing Director, Head of Regulatory Affairs and Sustainability

202.448.0856

sburki@crefc.org

David McCarthy

Managing Director, Chief Lobbyist, Head of Legislative Affairs

202.448.0855

dmccarthy@crefc.org

James Montfort

Manager, Government Relations

202.448.0857

jmontfort@crefc.org

Latest News

News

CREFC and NCREIF Launch Open-End Moderate-Yield Debt Fund Index

December 5, 2025

NEW YORK, December 5, 2025 – The CRE Finance Council (CREFC) and the National Council of Real Estate Investment Fiduciaries (NCREIF) announce the launch of the NCREIF/CREFC Fund Index Open-End Moderate-Yield Debt, the first-ever institutional fund-level benchmark for private real estate debt funds. As of June 30, 2025, the Index comprises 12 open-end debt funds representing more than $30 billion in assets and over 500 underlying loans with posted returns since the fourth-quarter 2017, providing a robust, representative measure of performance for the sector.

Developed jointly by NCREIF and CREFC, the Moderate-Yield Debt Index fills a long-standing market need for a standardized, transparent benchmark that reflects the risk-return characteristics of actively managed open-end commercial real estate debt strategies.

Consultation Phase. The Moderate-Yield Debt Index will be issued in a consultation phase for one to two years to solicit the appropriate level of feedback from industry professionals and ensure the index’s methodology and governance align with market expectations. During this period NCREIF and CREFC will engage stakeholders on methodology refinements, data standards, and reporting practices. After the initial consultation, if appropriate, the NCREIF/CREFC Fund Index Open-End Moderate-Yield Debt will be memorialized as an official NCREIF/CREFC product.

CREFC and NCREIF also publish an Open-End Debt Fund Aggregate, a research database of funds with a mix of Core, Moderate-Yield and High-Yield investment styles. New data contributors are welcome for both the Aggregate and the Moderate-Yield Debt Index. Depending on market demand and growth of the open-end private real estate debt fund space, Core-Yield and/or High-Yield Debt Indices may be possible in the future.

For more information or to provide feedback, please contact Lisa Pendergast at LPendergast@CREFC.org or Dan Dierking at DDierking@NCREIF.org.

Media Contact:
Mary Beth Ryan
Senior Director, Communications
646-884-7567
mryan@crefc.org

Contact

Mary Beth Ryan
Senior Director,
Communications
646.884.7567
mryan@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.

CREFC and NCREIF Launch Open-End Moderate-Yield Debt Fund Index

December 5, 2025

The CRE Finance Council (CREFC) and the National Council of Real Estate Investment Fiduciaries (NCREIF) announce the launch of the NCREIF/CREFC Fund Index Open-End Moderate-Yield Debt.

More info...

News

Community Opportunity to Purchase (COPA) Act on NYC Council Agenda

November 25, 2025

A New York City Council proposal could materially reshape multifamily transactions across the country’s largest rental market, New York City.

The bill would apply to every NYC residential building with three or more units and would create a city-administered first-offer and matching-right process for approved nonprofits and community land trusts.

Why it matters: As drafted, the broad scope of the legislation would apply an additional waiting period and processes to every multifamily building in the city.

Industry participants are concerned that mandatory standstill periods and discretionary extensions could introduce long, unpredictable delays into ordinary sales, chill competitive bidding, and increase transaction and operation costs.
Supporters argue COPA would help preserve and expand affordable housing by giving mission-driven buyers an opportunity to acquire inventory before displacement or speculative repositioning occurs.

Go deeper: Under COPA, a multifamily owner planning to sell would have to file a notice with the New York City Department of Housing Preservation and Development (HPD) 180 days in advance and provide a detailed package of property and financial information.

A qualified buyer will have 120 days from the date of notice to submit an offer, during which time the seller may not accept any outside offers with HPD having discretion to extend timelines. Noncompliance could trigger civil penalties of up to $30,000.

Each seller must provide to HPD:

Building address, the type of sale and estimated sale date, the provision of law, rule, or regulation pursuant to which such action is authorized, if any, and number of dwelling units.
The rent roll, a 12-month income and expense statement, the amount of outstanding debt, the two most recent inspection reports conducted by HPD or the New York City Department of Buildings, if any, and any other information HPD may require.

The bottom line: For lenders and capital-markets participants, the slower, less certain transactions and heavier disclosure burdens could weaken liquidity, complicate financing execution, and ultimately pressure valuations in the New York City market.

What’s next: CREFC is working with its local partners to analyze the proposal and discuss next steps.

Contact David McCarthy (dmccarthy@crefc.org) with questions or to get involved.

Contact

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

News Archive

Community Opportunity to Purchase (COPA) Act on NYC Council Agenda

November 25, 2025

A New York City Council proposal could materially reshape multifamily transactions across the country’s largest rental market, New York City.

More info...

News

FHFA Raises Multifamily Caps by $30 Billion

November 25, 2025

On November 24, the Federal Housing Finance Agency (FHFA) announced that the 2026 multifamily loan purchase caps for Fannie Mae and Freddie Mac (the Enterprises) will be $88 billion for each Enterprise, for a combined total of $176 billion.

Caps Increased to $88 billion: This is an increase from the $73 billion loan purchase caps per Enterprise in 2025.
FHFA will closely monitor the multifamily mortgage market and may increase the caps if necessary. Should the actual size of the 2026 market be smaller than initially projected, FHFA will not reduce the caps.
50% Mission-Driven Maintained: To maintain a strong emphasis on affordable housing and underserved markets, FHFA will continue to require that at least 50% of the Enterprises’ multifamily businesses be mission-driven, affordable housing.
Workforce Housing Continues to Be Exempt from Caps: To further promote affordable housing preservation, loans classified as supporting workforce housing properties in the definitions will remain exempt from the volume caps. (All other mission-driven loans remain subject to the volume caps.)

Go deeper: CLICK HERE for CREFC’s Side-by-Side analysis of the 2026 Multifamily Caps.

Please contact Sairah Burki at sburki@crefc.org or David McCarthy at dmccarthy@crefc.org with any questions.

Contact

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

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

News Archive

FHFA Raises Multifamily Caps by $30 Billion

November 25, 2025

On November 24, the Federal Housing Finance Agency (FHFA) announced that the 2026 multifamily loan purchase caps for Fannie Mae and Freddie Mac (the Enterprises) will be $88 billion for each Enterprise, for a combined total of $176 billion.

More info...

News

CREFC Sponsors Breaking Ground Gala

November 25, 2025

What happened: CREFC was proud to be a sponsor of Breaking Ground's Celebrating Home and Community Gala last month. CREFC members and leadership attended the inspiring evening, which raised more than $3.5 million to support homeless and vulnerable New Yorkers.

Through its residences and outreach programs across Brooklyn, Queens, and Manhattan, Breaking Ground touches the lives of over 13,000 New Yorkers each year, providing safe, permanent housing and comprehensive support services.

CREFC is honored to stand alongside Breaking Ground in their essential work building and restoring lives throughout our community.

Contact Mary Beth Ryan (MRyan@crefc.org) with any questions.

Contact

Mary Beth Ryan
Senior Director,
Communications
646.884.7567
mryan@crefc.org

Pictured, from left: Rohit Narayanan, Edward DeAngelo, and Raj Aidasani

News Archive

CREFC Sponsors Breaking Ground Gala

November 25, 2025

CREFC was proud to be a sponsor of Breaking Ground's Celebrating Home and Community Gala last month.

More info...

News

Congressional Update: Housing Legislation in Flux

November 25, 2025

As we’ve previously covered, the ROAD to Housing Act passed the Senate after being tacked onto the annual National Defense Appropriations Act (NDAA). However, certain House leaders have indicated they may not accept the whole bill and would instead prefer negotiated package.

Why it matters: While the housing legislation had unanimous support in the Senate Banking Committee prior to passage, the House had not been engaged in negotiations and not all the provisions have majority party support in that chamber.

Legislation attached as an amendment to a larger, non-relevant bill usually requires sign-off from the “four-corners,” which includes the Republican and Democratic leadership of the relevant congressional committee.
For the ROAD to Housing Act to be included in NDAA, the House Financial Services Committee (HFSC) and the Senate Banking Committee would need to sign off: HFSC Chairman French Hill (R-AR); Ranking Member Maxine Waters (D-CA); Senate Banking Chairman Tim Scott (R-SC); and Ranking Member Elizabeth Warren (D-MA).

What they’re saying: According to Politico, HFSC Chairman Hill rejected the housing legislation inclusion in the NDAA.

Hill has told his counterparts that he is hopeful about the prospects of a bicameral deal and supports some provisions of the Senate’s ROAD bill, according to a House GOP aide with knowledge of the matter. But he has said throughout the negotiations that some portions of the Senate plan are unpalatable to the majority of House Republicans and therefore cannot be tucked into the NDAA, the aide said. -Politico

Yes, but: Both parties remain committed to acting on housing legislation, and the HFSC will hold a hearing on housing supply on Dec. 3. The committee is expected to mark up legislation on housing in the near-term too.

What’s next: The NDAA text is expected when Congress returns after Thanksgiving, but it is not likely to include housing provisions as of now. Still, lawmakers will have other opportunities to advance compromise legislation in 2026 with the January 30 spending deadline or on other must-pass priorities.

Contact David McCarthy (dmccarthy@crefc.org) with questions.

Contact

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

News Archive

Congressional Update: Housing Legislation in Flux

November 25, 2025

As we’ve previously covered, the ROAD to Housing Act passed the Senate after being tacked onto the annual National Defense Appropriations Act (NDAA).

More info...

News

Deposit Insurance Hearing Overview

November 25, 2025

The House Committee on Financial Services held a hearing on November 18, 2025, titled “The Future of Deposit Insurance: Exploring the Coverage, Costs, and Depositor Confidence.” The hearing focused on whether the U.S. deposit insurance framework remains fit for purpose after the 2023 regional bank failures.

Members and witnesses examined the banking sector’s resilience, the role of regulatory oversight, and various approaches to reforming deposit insurance coverage. The witness list included:

Mr. James Ryan, Chairman and Chief Executive Officer, Old National Bancorp
Mrs. Jill Castilla, President and Chief Executive Officer, Citizens Bank of Edmond
Mr. Chris Furlow, President and Chief Executive Officer, Texas Bankers Association
Mr. Grover Norquist, Founder and President, Americans for Tax Reform
Mr. Jarryd E. Anderson, Partner and Co-Chair, Financial Services Group, Paul, Weiss, Rifkind, Wharton & Garrison LLP

What they’re saying: Discussion centered on uninsured transaction balances, depositor behavior in crises, and potential impacts on community, regional, and large banks.

The issue of increasing deposit insurance largely fell along party lines, with support from Ranking Member Maxine Waters (D-CA), and disapproval from Chairman French Hill (R-AR).
Much of the discussion focused on the Hagerty-Alsobrooks proposal, also known as the Main Street Depositor Protection Act (S. 2999). This bill would:
- Expand coverage for business operating accounts: If enacted, this bill would raise FDIC/NCUA insurance to $10M per depositor for non-interest-bearing transaction accounts at eligible banks and credit unions. The aim is to reduce run risk and help smaller banks compete with “too-big-to-fail” giants.
- Cost shielding/structure: A 10-year transition period would prevent community banks with less than $10B in assets from higher assessments or increased premiums tied to the new coverage.
Many members and witnesses supported a reimagining of the Temporary Liquidity Guarantee Program (TLGP). The temporary FDIC crisis program started in 2008 during the GFC and fully insured non-interest-bearing transaction accounts above the normal limit.
ETAG: Members discussed creating a new similarly designed program called the Emergency Transaction Account Guarantee (ETAG), as that would let FDIC/NCUA quickly guarantee transaction accounts system-wide during a panic for a limited time.
- It was noted that with the speed of electronic transactions, this program would need be deployed at the beginning of a crisis to operate effectively.
- The ETAG program had bipartisan interest, with many witnesses and members in favor of ETAG reform proposals.
- Rep. Barr (R-KY) questioned Mr. Furlow as to how ETAG could be preferable to an increase in deposit insurance. Mr. Furlow noted that ETAG would apply to all banks equally and ensure they are safe during a crisis. he notes that it is a reactive measure to a crisis, while increasing deposit insurance is a measure taken beforehand.
Data collection: Members on both sides of the aisle raised concerns that the FDIC does not collect enough data to monitor uninsured deposits and that a thorough review of the data that is needed will be crucial before reforms can be made.

What they’re saying: Witnesses split into two camps. Bank CEOs and trade groups supported targeted higher coverage for non-interest-bearing business transaction accounts used for payroll and operations.

Old National’s James Ryan said about 30% of his bank’s deposits are uninsured and argued that $10M coverage for these accounts would protect most mid-sized bank relationships, helping community and regional banks compete against perceived “too-big-to-fail” large banks.
Skeptics led by Grover Norquist argued coverage is sufficient. According to their testimony, nearly 99% of accounts have under $250K, and the 2023 failures were supervisory and management breakdowns, not insurance shortfalls.
The skeptics warned that higher guarantees create moral hazard and act like an industry tax passed to consumers.

Deposit Insurance Level Raise: Chairman Hill (R-AR) questioned whether increasing the limit to $10M per depositor is needed noting that 99% of depositors fall under the current $250k limit. He also noted that the failure of Silicon Valley Bank was at its core a management problem.

Let’s be clear. Deposit insurance was not the cause of those bank failures. The banks were insolvent and increased deposit insurance wouldn’t have fixed that.

Additionally, Rep. Andy Barr (R-KY) noted that increasing the limit could created “moral hazard” and that the liability could be shifted to taxpayers if the deposit limit is increased.

Rep. Maxine Waters (D-CA) noted that her bill, the Employee Paycheck and Small Business Protection Act would raise deposit insurance levels for business payroll/operating accounts after a FDIC/NCUA study. Waters also supports giving regulators authority to rapidly launch a TAG-style emergency guarantee to stop contagion.

Separately, Rep. Frank Lucas (R-OK) landed somewhere in the middle on both proposals, noting that he supports “targeted reform” and that banks of different sizes have different needs.

The takeaway: The hearing showed growing bipartisan momentum for a TAG/ETAG-style emergency backstop. There was sharp disagreement over making large permanent FDIC limit hikes without better data on costs, moral hazard, and Deposit Insurance Fund risk.

Contact James Montfort (jmontfort@crefc.org) with any questions.

Contact

James Montfort
Manager,
Government Relations
202.448.0857
jmontfort@crefc.org

News Archive

Deposit Insurance Hearing Overview

November 25, 2025

The House Committee on Financial Services held a hearing on November 18, 2025, titled “The Future of Deposit Insurance: Exploring the Coverage, Costs, and Depositor Confidence.”

More info...

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Advocacy

CREFC Government Relations: Shaping Our Industry

CREFC PAC

Strengthening Your Voice in Washington, D.C.

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ELECTIONS

Get Involved

PCM

Policy and Capital Markets Briefing

Recent Headlines from our Sept. 16th, 2025 issue

PCM Stories Samples

CREFC POLICY TRACKERS

CREFC Policy Trackers

CREFC Comment Letters

Regulatory Agency Leadership Matrix: PCM report

Forums Policy Matrix

Election Scenario Analysis: PCM report

Risk & Resilience Committee

Introducing CREFC’s Property Risk & Resilience Committee

What We Do

Our work includes:

Why This Matters

CREFC Advocacy Staff

Latest News

News

CREFC and NCREIF Launch Open-End Moderate-Yield Debt Fund Index

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News

Community Opportunity to Purchase (COPA) Act on NYC Council Agenda

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News

FHFA Raises Multifamily Caps by $30 Billion

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News

CREFC Sponsors Breaking Ground Gala

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News

Congressional Update: Housing Legislation in Flux

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News

Deposit Insurance Hearing Overview

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