Comment

On behalf of the 1.5 million members of the National Association of REALTORS® (NAR), I submit this letter in response to the request for input (RFI), Amendments to the Enterprise Regulatory Capital Framework Rule – Prescribed Leverage Buffer Amount and Credit Risk Transfer (RIN 2590-AB17). NAR appreciates the efforts of the Federal Housing Finance Agency (FHFA) to address problems created by the high leverage rule and onerous treatment of credit risk transfer (CRT) in the enterprise regulatory capital framework (ERCF). However, REALTORS® believe that the ERCF must be further refined: the buffers included in the risk-based rule remains too high; the minimum risk weight for single family loans and the minimum for CRT are too high; the counter-cyclical buffer is problematic; the FHFA rule does not address the potential impact of an explicit guarantee on the Enterprises’ capital requirements; and the FHFA must be address the impact on fees of a risk-based capital rule for entities with charter obligations.  Further details are included in the attache comment letter.  If you have questions or comments, please direct them to Ken Fears, NAR’s Senior Policy Representative at (202) 383-1066 or KFears@NAR.REALTOR.