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

    Recap: Senate Hearing Focuses on Insurance Costs, Availability 

    May 6, 2025

    The Senate Banking Committee held a May 1 hearing titled Examining Insurance Markets and the Role of Mitigation Policies with the following witnesses:

    • Robert Gordon, Senior Vice President, Policy, Research & International, American Property Casualty Insurance Association (APCIA);
    • Alex Epstein, President and Founder, Center for Industrial Progress; 
    • Michael Newman, General Counsel, Insurance Institute for Business and Home Safety (IBHS); and 
    • Jessica Pyska, Supervisor, County of Lake, California 

    During the hearing, senators and witnesses cited several underlying drivers of the higher cost and lower availability of property insurance, including:

    • Demographic shifts to areas with higher climate risk,
    • Inflation, particularly related to building materials;
    • Legal system abuse, and 
    • Regulatory limitations.

    They also raised concerns about discriminatory practices, market competition, and how federal policy shifts, including tariffs, affect cost volatility across states.

    Disaster mitigation, infrastructure resilience, and forest management featured prominently as strategies to lower long-term insurance costs. 

    • Committee members and witnesses engaged in detailed discussions about property resilience efforts. Ms. Pyska affirmed the importance of hardening homes and discussed Lake County's attempts to "cluster harden" entire communities with wraparound fire breaks to ensure the entire community is resilient.
    • Sen. Warner (D-VA) noted the U.S. Chamber of Commerce suggested that every $1 invested in resilience and disaster preparation reduces a community's economic costs by $7.
    • However, it is not clear whether resilience efforts have thus far resulted in lower insurance costs for property owners.
    Multiple members criticized cuts to federal programs like Building Resilient Infrastructure and Communities Grants (BRIC) and other grants provided by the Federal Emergency Management Agency (FEMA). 

    • Sen. Andy Kim (D-NJ) raised concerns about efforts to privatize or eliminate the National Flood Insurance Program (NFIP), questioning whether the private sector is equipped to absorb these costs while keeping insurance premiums low. 
    • APCIA’s Gordon explained that the NFIP, which covers 4.7 million households, charges significantly less than the private market. He also stressed the important role NFIP plays in encouraging community floodplain management and developing flood maps, and building codes. 
    • To listen to a podcast in which CREFC’s Sairah Burki and David McCarthy share their thoughts about the NFIP with The Commercial Property Executive’s Therese Fitzgerald, please click here.
    CREFC’s Property & Resilience Committee has closely covered CRE insurance issues over the past few years via presentations from experts, webinars, and panels at conferences. Please see here for more information and stay tuned for forthcoming webinars. 

    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
    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.
    Recap: Senate Hearing Focuses on Insurance Costs, Availability
    May 6, 2025
    The Senate Banking Committee held a May 1 hearing titled Examining Insurance Markets and the Role of Mitigation Policies.

    News

    Tax Update: House Delays Action on Bill

    May 6, 2025

    Republicans delayed the rollout and consideration of key elements of the reconciliation legislation, including hearings on tax policy legislation and changes to Medicaid.

    Why it matters: The House leadership still wants to pass a bill by Memorial Day, yet competing priorities among members of Congress and the White House are proving to be challenging. 

    By the numbers: The tax-writing House Ways and Means Committee was originally planning a markup on May 7, but that has been delayed to, at least, the week of May 12. Reports indicate lawmakers are close on many issues, but still have to agree on several key issues: 
     
    • SALT: Raising the individual state and local tax (SALT) deduction cap, currently $10,000, is still under debate. New York, New Jersey, and California Republicans have made raising this cap their “red line.” With a five-vote majority, they have enough votes to tank any bill without SALT relief. 
    • Business SALT Cap: Colloquially known as B-SALT or corporate C-SALT, this provision has been under active consideration in House discussions. No details have emerged on what specifically would be covered, but conflicting reports indicate it would be pared down or potentially not included.
    • Clean Energy Tax Credits: House Republicans have been targeting Inflation Reduction Act (IRA) tax programs as a way to reduce spending or offset some of the new tax cuts. But a group of 21 Republicans sent a letter in March urging leadership that any changes be “targeted and pragmatic” with a mind to future private-sector investment. Another group of 38 House Republicans sent a letter last week asking for a full repeal of the credits. 
    • White House Priorities: While the President made no taxes on tips, overtime, and social security key campaign priorities, the White House continues to offer additional items. Last week, the White House told congressional leaders it would seek immediate and full expensing treatment for factory construction, both the buildings and the equipment. 

    The big picture: The many loose ends on the tax front may contribute to a delay, but House leaders remain confident of meeting a May deadline. Challenges remain, however.

    • The brewing fight on Medicaid, which Democrats are focusing their energy on highlighting, is raising political alarms for some Republicans and even the White House.
    • Deficit hawks in the House continue to saber-rattle on spending cuts. Rep. Chip Roy (R-TX) and 20 House members sent a letter urging a number of “meaningful reforms” to Medicaid. 
    • The Senate is not planning to mark up legislation, but it will likely have a heavy hand in moderating taxes or cuts once a bill passes the House. 
    • The debt ceiling deadlines continue to loom over the entire legislation. Treasury is expected to clarify the “X date” in the next week or two. 

    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
    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.
    Tax Update: House Delays Action on Bill
    May 6, 2025
    Republicans delayed the rollout and consideration of key elements of the reconciliation legislation, including hearings on tax policy legislation and changes to Medicaid.

    News

    Legislation to Raise FHA Multifamily Income Limits 

    May 6, 2025

    Two freshmen senators unveiled a bipartisan bill last week that would raise the loan limit caps for Federal Housing Administration (FHA) multifamily loans administered by the Department of Housing and Urban Development (HUD). 

    Click here for the legislative text.

    Why it matters: FHA multifamily programs insure loans for construction, rehabilitation, repair, refinancing, and purchase of multifamily rental housing properties. 

    • Senator Ruben Gallego (D-AZ) and Senator Dave McCormick (R-PA) introduced the legislation. 
    • If enacted, the bill would raise the base FHA multifamily unit income limits that determine eligibility. Those income limits have not been updated since 2004, though they have been subject to annual inflation adjustments and high cost-of-living multipliers. 

    By the numbers: The bill would raise the base income thresholds and adjust the index for inflation: 

    • The inflationary adjustment index would change from the Consumer Price Index (CPI) to the Price Deflator Index of Multifamily Residential Units Under Construction (published by the Census Bureau).
    • Statutory threshold changes would impact the following HUD programs:
      • Section 207 – Multifamily Housing Insurance
      • Section 213 – Cooperative Housing
      • Section 220 – Urban Renewal Housing
      • Section 221 – Low- and Moderate-Income Rental and Cooperative Housing; 
      • Section 231 – Housing for Elderly Persons
      • Section 234 – Blanket Mortgage Insurance for Condos

    What’s next: Republicans and Democrats continue to be interested in lowering the cost of housing, both single-family and multifamily. 

    • If lawmakers find enough areas of bipartisan agreement, a larger housing-focused bill could move through Congress in the next year and a half. 
    • However, methods lowering the costs of housing through subsidies, direct assistance, or supply incentives can provoke sharp disagreements. 
    • While there are plenty of areas of bipartisan opportunity, the enactment of any housing policy, on a standalone basis or as a larger bill, will be challenging.

    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
    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.
    Legislation to Raise FHA Multifamily Income Limits
    May 6, 2025
    Two freshmen senators unveiled a bipartisan bill last week that would raise the loan limit caps for Federal Housing Administration (FHA) multifamily loans administered by the Department of Housing and Urban Development (HUD).

    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.

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