USMI COMMENT LETTER ON FHFA’S PROPOSED RULE ON “AMENDMENTS TO THE ENTERPRISE REGULATORY CAPITAL FRAMEWORK RULE”
On September 27, 2021, the Federal Housing Finance Agency (FHFA) published its Notice of Proposed Rulemaking (NPR) on “Amendments to the Enterprise Regulatory Capital Framework (ERCF) Rule – Prescribed Leverage Buffer Amount and Credit Risk Transfer.” On November 23, 2021, USMI submitted comments to the NPR, emphasizing the importance of setting appropriate, balanced, and analytically justified requirements for the government-sponsored enterprises (Enterprises), Fannie Mae and Freddie Mac, to simultaneously ensure their financial strength and borrowers’ continued access to affordable mortgage finance credit in the conventional market. USMI’s full comments can be found here, and an executive summary can be found here. USMI’s comments to FHFA’s 2020 ERCF can be found here and an executive summary can be found here. USMI’s comments on FHFA’s 2018 proposed Enterprise capital framework can be found here.