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.