Resource Filter: Letters

Letter: Comments on FHFA’s Proposed Rule on Enterprise Capital Requirements

Posted on by dcadmin

A Comment Letter from U.S. Mortgage Insurers

Alfred M. Pollard
General Counsel
Federal Housing Finance Agency
Eighth Floor
400 Seventh Street, SW
Washington, D.C. 20219


RE: Comments/RIN 2590-AA95


Dear Mr. Pollard:

This letter is submitted by U.S. Mortgage Insurers (USMI), a trade association comprised of the leading private mortgage insurance (MI) companies in the United States.0F1 Together, the private mortgage insurance industry has helped nearly 30 million homeowners over the past 60 years, including more than 1 million in the past year alone.

USMI is dedicated to a housing finance system backed by private capital that enables access to housing finance for all creditworthy borrowers while protecting taxpayers. USMI supports meaningful and appropriate capital requirements for Fannie Mae and Freddie Mac (the “Enterprises”) and appreciates the Federal Housing Finance Agency (FHFA) for initiating this rulemaking process, and for affording us an opportunity to submit comments.

Currently, the Enterprises use a FHFA-developed Conservatorship Capital Framework (CCF) to align business and pricing decisions (e.g. G-Fees) with economic risk. The notice of proposed rulemaking (NPR) states that during conservatorship, FHFA expects the Enterprises to “use assumptions about capital described in the rule’s risk-based capital requirements in making pricing and other business decisions,” even though the new standards will not be used to determine capital compliance until after the conservatorship ends.1F2 Therefore, the final regulation could have an immediate real-world impact on the Enterprises’ activities and the cost and availability of mortgage credit. As a result, this rulemaking is very significant for our members, other participants in housing finance, and the American public.

USMI’s full comments to FHFA can be found here.

Letter: Coalition Letter in Support of the Nomination of Mark Calabria

Posted on by dcadmin


The Honorable Mitch McConnell
Majority Leader
United States Senate
S-230, U.S. Capitol
Washington, DC, 20510

The Honorable Chuck Schumer
Minority Leader
United States Senate S-221, U.S. Capitol
Washington, DC 20510

Dear Majority Leader McConnell and Leader Schumer:

The undersigned organizations, representing a wide range of perspectives in the housing and mortgage finance industry, write to strongly encourage the confirmation of Dr. Mark Calabria as Director of the Federal Housing Finance Agency (FHFA).

A longtime public servant, Dr. Calabria is a respected expert in housing finance with detailed knowledge of the intricacies of the housing and mortgage finance markets. As one of the Congressional staffers who helped craft the Housing and Economic Recovery Act of 2008, Dr. Calabria has demonstrated a keen understanding of the critical role of the FHFA as both regulator and conservator of Fannie Mae and Freddie Mac (the “Enterprises”). Additionally, through his experience as a staffer on the U.S. Senate Committee on Banking, Housing, and Urban Affairs, and at the National Association of REALTORS®, National Association of Home Builders, and the U.S. Department of Housing and Urban Development, Dr. Calabria understands the need for FHFA to be transparent and methodical in its development and enforcement of policies.

The FHFA has an incredibly important mission of ensuring for a liquid and robust mortgage market, while regulating the Enterprises and their $5.4 trillion in mortgage credit risk, along with the Federal Home Loan Bank system.1 It is critical for the Senate to proceed expeditiously to confirm a permanent Director at the FHFA in order to best promote an efficient national secondary mortgage market that facilitates access to affordable mortgage financing for all creditworthy borrowers during all market conditions. Dr. Calabria recognizes the need to balance this mission with the protection of taxpayers from mortgage credit risk while avoiding market disruptions when improving and implementing policy. Any new Director should also maintain increased transparency with essential public feedback to guarantee that any potential changes are in the best interests of consumers, the supporting industries, and the overall economy.

Dr. Calabria has a deep understanding of the secondary mortgage market and the complex policy issues that affect the entities the FHFA oversees. Dr. Calabria’s decades of experience in the public and private sectors have prepared him to execute the duties of Director and address the agency’s mission and significant regulatory priorities.

We respectfully request the swift confirmation of Dr. Calabria as Director of the FHFA to protect and ensure the continuation of a strong real estate market and overall economy.

Sincerely,

American Academy of Housing and Communities
American Land Title Association (ALTA)
The Commercial Real Estate Finance Council (CREFC)
Community Associations Institute
Consumer Mortgage Coalition
Leading Builders of America
Make Room
Manufactured Housing Association for Regulatory Reform (MHARR) Manufactured Housing Institute
Mortgage Bankers Association
Nareit
National Affordable Housing Management Association
The National Apartment Association
National Association of Home Builders
The National Association of Housing Cooperatives
National Association of REALTORS®
National Council of State Housing Agencies
National Leased Housing Association
National Multifamily Housing Council
The Real Estate Roundtable
Real Estate Services Providers Council, Inc. (RESPRO)
The Realty Alliance
U.S. Mortgage Insurers

cc: United States Senate

For a full PDF of this letter click here.

Letter: USMI Joins Coalition in Support of Full Senate Vote on Pam Patenaude

Posted on by Rhina Portillo

USMI joined nearly 60 other organizations in supporting a full Senate vote on the nomination of Pam Patenaude as HUD Deputy Secretary. Click below to read the full coalition letter. Click here to download the letter as a PDF.

Letter: Comments on CFPB on the Ability-to-Repay/QM Rule

Posted on by Rhina Portillo

On July 31st, USMI submitted the following response to the request for comment regarding the Consumer Financial Protection Bureau’s notice of assessment of the Ability-to-Repay/Qualified Mortgage rule. USMI applauds the Bureau for undertaking an assessment of this critical rule that is aimed at enhancing lending standards and consumer protection, now that sufficient time has passed since it went into effect. As described in the letter, USMI encourages the Bureau to assess whether different QM standards across the various regulatory agencies have negatively impacted consumers. Click here to read the full letter.

DOWNLOAD AS PDF

Letter: USMI Welcomes Effort to Increase Reliance on Private Capital In Housing Finance

Posted on by dcadmin

USMI delivered the following letter to members of the Senate Banking Committee last night:

USMI Header 750
May 20, 2015

 

The Honorable Richard Shelby

Chairman
U.S. Senate Committee on Banking, Housing, and Urban Affairs
534 Dirksen Senate Office Building
Washington, DC 20510

Dear Chairman Shelby:

U.S. Mortgage Insurers (“USMI”) welcomes the effort to make progress on increasing the reliance on private capital in housing finance as part of consideration by the Senate Banking Committee of the Financial Regulatory Improvement Act of 2015.

Specifically, USMI supports Section 706, which calls on the Government Sponsored Enterprises (“GSEs”) to engage in front-end risk sharing transactions. This directive would make greater use of private capital to “de-risk” the GSEs, lower the exposure and costs for the enterprises and taxpayers and should lower costs to borrowers. USMI supports this effort, and will continue to work with the Committee during the legislative process on clarifications to ensure the legislation has the intended effect of being “transaction neutral” to permit a variety of methods of up front risk sharing, with all risk sharing counterparties held to equivalent standards.

Promotion of greater up front risk sharing will help build a strong, stable housing finance system that provides access to sustainable and affordable mortgage credit while protecting taxpayers. We look forward to favorable action on this important effort.

Sincerely,

 

U.S. Mortgage Insurers

cc: The Honorable Sherrod Brown, Ranking Member

All members of the Senate Banking Committee

Download as PDF

Press Release: USMI Supports Affordable Housing Principles and Calls for Transparency in FHFA Duty to Serve Plans

Posted on by dcadmin

USMI Header 750 - New Logo

USMI Supports Affordable Housing Principles and Calls for Transparency in FHFA Duty to Serve Plans

USMI submitted comments on the Federal Housing Finance Agency’s (FHFA’s) proposal for how the government sponsored housing enterprises Fannie Mae and Freddie Mac should serve underserved markets.  USMI supports both principles of facilitating the financing of affordable housing for low-to-moderate income families consistent with the Enterprises’ overall public purposes while maintaining a strong financial condition and reasonable economic return.  To that end, among other things USMI calls for full transparency into the economics of the Plans to ensure policy aims are met in the most efficient way available.  USMI looks forward to working with MI customers, FHFA, the Enterprises, and other market stakeholders to help the Enterprises meet their “Duty to Serve” obligations.  The text of the USMI comment letter can be found here.

###

U.S. Mortgage Insurers (USMI) is dedicated to a housing finance system backed by private capital that enables access to housing finance for borrowers while protecting taxpayers. Mortgage insurance offers an effective way to make mortgage credit available to more people. USMI is ready to help build the future of homeownership.  Learn more at www.usmi.org.

 

Download as PDF

Letter: Joint Letter on G-fees

Posted on by dcadmin

USMI Joins Letter on G-fees

In letters to House and Senate Budget Committee leadership, USMI joined a broad group of more than a dozen housing organizations urging Congress to use GSE G-fees for their intended purpose, to support homeownership stability.

“By preventing g-fees to be used as a funding offset, this budget point of order gives lawmakers a vital tool to prevent homeowners from footing the bill for unrelated spending,” the letters said. “We urge you to once again include it in this year’s Budget Resolution.”

Click here for the full text of the House and Senate letters.

Comment Letter: USMI Joins Coalition on Highway Bill Funding

Posted on by dcadmin

(November 10, 2015) In a letter to conferees on the pending highway bill, USMI joined a broad coalition of 27 housing organizations in urging conferees to draw funds from the Federal Reserve’s surplus, rather than using GSE G-fees, to pay for the extension of the Highway Trust Fund.

The full text of the letter can be found here

Letter: Opposition Builds Against Using Mortgage G-Fees to Fund Highway Bill

Posted on by dcadmin

(September 17, 2015) This week, in a joint letter to the bipartisan Congressional leadership, USMI and a diverse coalition of thirty-two housing organizations reiterated their opposition to using the mortgage credit risk guarantee fees (g-fees) charged by the housing finance enterprises, Fannie Mae and Freddie Mac, as a source to finance extension of federal highway programs.  The letter states: “increasing g-fees for other purposes… imposes an unjustified burden on the housing finance system.”  “Adding an additional fee to mortgages for unrelated expenses would only increase the hurdles these families already face in achieving the American dream of homeownership”, it continues.

The full text of the letter can be found here

Letter: USMI Joins Broad Coalition Opposing Use of G-Fees To Fund Highway Bill

Posted on by dcadmin

(July 23, 2015) This week, USMI joined a broad coalition of nine other housing groups to send a letter to Senate leadership opposing the use of the credit risk guarantee fees (g-fees) charged by the housing finance enterprises, Fannie Mae and Freddie Mac, as a source of funding for the extension of federal transportation programs.  The letter states: “whenever Congress has considered using g-fees to cover the cost of programs unrelated to housing, our members have united to emphatically let Congress know that homeownership cannot, and must not, be used as the nation’s piggybank.”

The full text of the letter can be found here.

Letter: USMI Welcomes Effort to Increase Reliance on Private Capital In Housing Finance

Posted on by dcadmin

USMI delivered the following letter to members of the Senate Banking Committee last night:

USMI Header 750
The Honorable Richard Shelby

Chairman
U.S. Senate Committee on Banking, Housing, and Urban Affairs
534 Dirksen Senate Office Building
Washington, DC 20510

Dear Chairman Shelby:

U.S. Mortgage Insurers (“USMI”) welcomes the effort to make progress on increasing the reliance on private capital in housing finance as part of consideration by the Senate Banking Committee of the Financial Regulatory Improvement Act of 2015.

Specifically, USMI supports Section 706, which calls on the Government Sponsored Enterprises (“GSEs”) to engage in front-end risk sharing transactions. This directive would make greater use of private capital to “de-risk” the GSEs, lower the exposure and costs for the enterprises and taxpayers and should lower costs to borrowers. USMI supports this effort, and will continue to work with the Committee during the legislative process on clarifications to ensure the legislation has the intended effect of being “transaction neutral” to permit a variety of methods of up front risk sharing, with all risk sharing counterparties held to equivalent standards.

Promotion of greater up front risk sharing will help build a strong, stable housing finance system that provides access to sustainable and affordable mortgage credit while protecting taxpayers. We look forward to favorable action on this important effort.

Sincerely,

U.S. Mortgage Insurers

cc: The Honorable Sherrod Brown, Ranking Member

All members of the Senate Banking Committee

Download as PDF