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

    FHFA Rescinds Multifamily Lease Policies

    March 26, 2025

    Newly appointed Federal Housing Finance Agency (FHFA) Director William Pulte published orders on social media platform X on March 24, rescinding a 2024 FHFA directive entitled “Aligned Policies on Multifamily Rental Payment Flexibility and Lease Notices.”

    Why it matters: The order eliminates a Biden-era policy requiring that GSE multifamily loan documents mandate various notices and grace periods for tenants. 

    Background: In July 2024, the FHFA announced mandatory tenant protections, via loan agreements, for multifamily properties financed by Fannie Mae and Freddie Mac (the GSEs). The effort was part of a broader push to examine tenant protection policies at the GSEs, including possible rent control. 
     
    • The July 2024 press release noted that this is “the first time that tenant protections will be a standard component of Enterprise multifamily financing.”
    • Effective February 28, 2025, covered housing providers would have been required to provide tenants with the following:
      • 30-day written notice of a rent increase;
      • 30-day written notice of a lease expiration; and
      • 5-day grace period for rent payments.

    Yesterday, Pulte also ordered the rescission of an advisory bulletin requiring the GSEs to develop a “climate-related risk management framework into its existing enterprise risk management program.”

    As covered in CREFC’s most recent Policy and Capital Markets Briefing, last week Pulte revamped the boards of both Fannie Mae and Freddie Mac and is now chair of each board. Freddie Mac CEO Diana Reid was let go and FHFA Chief Operating Officer Gina Cross and Human Resources Director Monica Matthews were placed on leave.

    Please 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.
    FHFA Rescinds Multifamily Lease Policies
    March 26, 2025
    The order eliminates a Biden-era policy requiring that GSE multifamily loan documents mandate various notices and grace periods for tenants.

    News

    Proposed Georgia Bill Caps Institutional Housing Ownership

    March 25, 2025

    The Georgians First Residential Property Protection Act (HB 555), a bill in the Georgia state legislature, would limit business enterprises from owning more than 2,000 single-family homes or 10 multifamily properties in the state. 

    Why it matters: The measure, sponsored by four Republicans and one Democrat, demonstrates increasingly bipartisan political concern over single-family rentals (SFR), but the limitation on multifamily property ownership signals a new pushback on institutional ownership of housing.

    Go deeper: An updated version of the bill discussed in committee removed the multifamily language and provided transition language to allow businesses to reduce their exposure through 2029. 
     
    • In a committee hearing on March 3, the bill sponsor testified in support of a revised bill expressing concern about increased corporate ownership of SFRs in Georgia. The sponsor cited data that indicated no institution owned more than 1,000 single-family homes prior to 2011.
    • Enforcement would be through a private right of action rather than state enforcement against businesses that own more than 2,000 homes. 
    • The bill was reported favorably out of the Georgia House Judiciary Committee with only one legislator voting in opposition. The full state House has not yet acted on the bill. 

    The big picture: Georgia legislative observers indicate the bill likely will not advance further this session. 

    • However, the near-unanimous committee approval with 12 Republicans and five Democrats on the committee indicates the growing local concern on the issue.
    • On the federal level, legislation targeting institutional ownership has been limited to Democrats, but moderates have been joining with progressives in supporting the legislation.
    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.
    Proposed Georgia Bill Caps Institutional Housing Ownership
    March 25, 2025
    The Georgians First Residential Property Protection Act (HB 555), a bill in the Georgia state legislature, would limit business enterprises from owning more than 2,000 single-family homes or 10 multifamily properties in the state.

    News

    FinCEN Limits Corporate Transparency Act Scope

    March 25, 2025

    Treasury’s Financial Crimes Enforcement Network (FinCEN) published an interim final rule exempting U.S. companies and U.S. persons from the beneficial ownership information (BOI) reporting requirements of the Corporate Transparency Act (CTA). Secretary Scott Bessent had previewed the change earlier this month. 

    Why it matters: As we previously covered, the CTA has faced regulatory delays and numerous court challenges, particularly from small businesses.

    What they're saying: In a press release announcing the rule change, Treasury described the changes as follows:

    • Revises the definition of a “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and have registered to do business in any U.S. state or Tribal jurisdiction by filing a document with a secretary of state or similar office (formerly known as “foreign reporting companies”).
    • Exempts entities previously defined as “domestic reporting companies” from the BOI reporting requirements.
    • Clarifies that foreign entities will not be required to report any U.S. persons as beneficial owners.
    • Also, U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.

    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.
    FinCEN Limits Corporate Transparency Act Scope
    March 25, 2025
    Treasury’s Financial Crimes Enforcement Network (FinCEN) published an interim final rule exempting U.S. companies and U.S. persons from the beneficial ownership information (BOI) reporting requirements of the Corporate Transparency Act (CTA). Secreta

    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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