NAR submitted comments to the FHFA on its notice of proposed rule making for how the FHFA and GSEs should plan for the resolution of either Enterprise in the case of their insolvency.
NAR thanked the FHFA for its efforts to establish a safe and sound framework for the enterprises to perform their charter duties throughout the solvency resolution process. However, NAR believes that the Enterprises would be better supported to meet their charter duties if designated Systemically Important Financial Market Utilities (SIFMUs). Furthermore, despite recognizing their critical market function, the FHFA's proposed rule assumes a limited or no government support in a crisis. NAR recommended that the FHFA analyze the benefits and costs of an explicit, paid for guarantee on GSE's securities, their charter duties, or some combination of the two and make recommendations to Congress to work toward that goal.