ABA Letter to FHFA on the Designation of Replacement for FHFAs ARM Index

The American Bankers Association (ABA) appreciates this opportunity to provide comments on the notice designating replacement for the Federal Housing Finance Agency’s ARM Index. The ARM Index based on the Monthly Interest Rate Survey (MIRS) was discontinued on May 29, 2019 due to dwindling participation by mortgage originators supplying MIRS data, but was replaced with an equivalent index on July 1, 2019.

Through the May 29 release, the ARM Index has been made available by FHFA or its predecessors on a monthly basis for about 45 years, making it one of the oldest existing mortgage rate data series. Although this index has been in less ubiquitous use than was once the case, it is still an important index for a number of community banks. Continuation of the data series serves an essential purpose and fills a consumer need.