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Garth Rieman
District of Columbia
National Council of State Housing Agencies
Rule Number:
Federal Register Citation:
85 FR 39274
12 CFR Part 1240
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View Document 1.91 MB


On behalf of the nation’s state Housing Finance Agencies (HFAs), the National Council of State Housing Agencies  (NCSHA) writes in response to the Federal Housing Finance Agency’s (FHFA’s) request for comments on its notice of proposed rulemaking on the Enterprise Regulatory Capital Framework (the Framework). 

While we fully understand the importance of establishing new regulatory capital rules for Fannie Mae and Freddie Mac (“the Enterprises”), the Framework as proposed is so badly flawed NCSHA urges FHFA to rescind it. 

FHFA should restart the rulemaking process with a more holistic approach that considers not only the Enterprises’ obligation to facilitate liquidity – which the Framework acknowledges – but also their mandates to support financing for affordable multifamily housing and facilitate the availability of single-family mortgage financing nationwide – which the Framework all but ignores.

FHFA also should publish any research it or the Enterprises have conducted on how the capital standards will impact the Enterprises’ ability to support financing for affordable single-family and multifamily lending and promote access to credit in the underserved markets the Enterprises are statutorily required to serve. 

The balance of this letter provides brief overviews of state HFAs and their partnership with the Enterprises; summarizes NCSHA’s comments on the Framework; and provides our detailed comments on the Framework.

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