USMI Comment Letter on FHFA’s Proposed Rule on the Enterprise Regulatory Capital Framework
On June 30, 2020, the Federal Housing Finance Agency (FHFA) published a Notice of Proposed Rulemaking (NPR) on the Enterprise Regulatory Capital Framework (ERCF). On August 31, USMI submitted comments to the NPR, emphasizing the importance of constructing a balanced, transparent, and analytically justified framework. USMI’s full comments can be found here and an executive summary can be found here. In 2018, FHFA issued a prior proposal for changing the risk-based capital framework for the GSEs. USMI also submitted a comment letter, which can be found here.