Statement: FHFA’s Re-Proposed Enterprise Capital Rule

May 21, 2020

WASHINGTON — Lindsey Johnson, President of U.S. Mortgage Insurers (USMI), today issued the following statement on the Federal Housing Finance Agency’s (FHFA) Re-Proposed Rule on Enterprise Capital:

“USMI supports meaningful and appropriate capital requirements for Fannie Mae and Freddie Mac (the GSEs) and appreciates the FHFA re-proposing a rule to achieve that goal. The Rule on Enterprise Capital is one of the most significant rules that FHFA will issue. The rule will determine the future role of the GSEs, how private capital will be able to continue to support the conventional market to protect taxpayers, and importantly, the level of access and affordability of mortgage finance credit for consumers.

“It is critical for the FHFA to create a capital framework for the GSEs that strikes an appropriate balance between maintaining borrowers’ access to affordable mortgage credit and ensuring the GSEs and taxpayers are protected from mortgage credit risk. To better shield taxpayers from mortgage credit risk, it is critical that capital requirements be tailored to the GSEs’ business operations, be counter-cyclical to withstand future downturns, and fully recognize the risk reduction associated with private mortgage insurance and equivalent forms of loan-level credit enhancement.

“In our 2018 comment letter on the original proposed capital rule, we also detailed a post-conservatorship capital regime for the GSEs to supersede the 2017 Conservatorship Capital Framework (CCF) that was then in effect. USMI specifically addressed three overarching areas within the proposed rule: 1) the Process and Transparency of the Development of the Proposed Framework; 2) the Overall Appropriateness of the Proposed Capital Requirements; and 3) the Treatment of Counterparties.

“USMI looks forward in reviewing this new re-proposed Enterprise Capital Rule that is very significant for our members, other participants in the housing finance industry, and the American public.”

The FHFA originally introduced the Rule on Enterprise Capital in 2018. USMI submitted a comment letter stating that its members support the goal of developing and implementing appropriate capital requirements for the GSEs that are clear, deliberative, and analytically justified.


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