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NAR submitted a letter to the Federal Housing Finance Agency (FHFA) in response to the agency’s request for input (RFI) on its proposed capital framework for Fannie Mae and Freddie Mac (the GSEs or Enterprises). The proposed framework would not be implemented until the Enterprises are taken out of conservatorship.
While NAR appreciates the FHFA’s efforts to reform the secondary mortgage market, NAR believes that the FHFA’s proposed framework could hamper the Enterprises’ ability to fulfill their public mission of supporting liquidity and broad access. In particular, the capital rule must do more to preserve the Enterprises’ countercyclical role in the market as well as to support affordable credit for a middle class and underserved homebuyers. The conservative nature of the capital framework as proposed may make this difficult.