CUNA filed a comment letter this
week expressing support for the Federal Housing Finance Agency’s (FHFA) efforts
to build a strong Enterprise liquidity framework. The letter states that: “The Enterprises are systemically
important and having formal liquidity requirements ensures safety and soundness
and helps provide overall operational and economic security, which should
prevent disruptions and increase the likelihood of a smoothly operating housing
finance function. It is also an obvious signal to the marketplace that this
issue matters, which can help to boost market confidence.”
The letter also encourages the
FHFA to pay special attention to the potential risks to non-bank
seller/servicers in periods of tight liquidity.