Removing Barriers Blog

CUNA Files Two Comment Letters to the FHFA
Posted November 15, 2018 by dyi

Today, CUNA filed the two attached comment letters with the Federal Housing Finance Agency. Summaries of the letters are below:

  1. Proposed Rule on the Uniform Mortgage-Backed Security – CUNA’s comment letter applauded the FHFA’s effort to address investor concerns surrounding the Uniform Mortgage-Backed Security before the security is launched in the To-Be-Announced Market on June 9, 2019.  In the letter, CUNA also emphasized the need for an orderly transition to a new system as part of housing finance reform efforts.

  1. Proposed Rule on Enterprise Capital Requirements – CUNA’s comment letter welcomed FHFA’s efforts to adopt strong capital requirements, but expressed concern about the lack of FHFA’s analysis of the impact the proposed capital requirements would have on the cost of conventional mortgage credit in the primary market. CUNA urged FHFA to conduct that analysis prior to the adoption of a final rule in order to ensure an appropriate balance between ensuring that the GSEs are adequately capitalized and ensuring that conventional mortgages remain affordable.