Letter to FHFA on Prior Approval of New GSE Products, Activities

The Honorable Mark Calabria
Director
Federal Housing Finance Agency
400 7th Street, SW
Washington, DC 20219

Dear Director Calabria,

The American Bankers Association (ABA) appreciates this opportunity to comment on the Federal Housing Finance Agency’s (FHFA or Agency) notice of proposed rulemaking on approval of Enterprise products. If finalized, the new rules would replace a 2009 Interim Final Rule, would take effect immediately, and would remain in place even after conservatorship of the GSEs ends.

ABA welcomes the FHFA’s effort to bring greater transparency and objectivity to the approval process for new products offered by the GSEs. Ensuring that the GSEs’ activities remain focused on the secondary market and do not stray into competition with primary market participants is a key responsibility of the FHFA. This proposal improves upon the existing rule in providing a more objective and clear construct for the evaluation and approval – or disapproval – of new activities and products. Nevertheless, we believe that the rule can be improved in a number of ways to further reduce subjectivity and ensure appropriate input from the public and impacted industry participants. We also recommend that FHFA make revisions and seek further comment before finalizing the rule.

Download the comment letter to read the full text.