NCSHA Comment Letter on FHFA’s Proposed Amendments to GSE Capital Standards
On May 12, 2023, NCSHA sent this letter to the Federal Housing Finance Agency (FHFA) in response to its proposed rule modifying several provisions of the Enterprise Regulatory Capital Framework (ERCF) for Fannie Mae and Freddie Mac. NCSHA expressed strong support for a provision of the proposed rule that would reduce by 40 percent the risk multiplier for multifamily mortgages backed by properties receiving government subsidies, including the Housing Credit. NCSHA urged FHFA to consider reducing the risk multiplier further and also to apply it to properties receiving funding through the HOME Investment Partnership program and from tax-exempt multifamily housing bonds. Additionally, the letter expressed support for FHFAโs proposals to reduce the risk weighting for commingled mortgage-backed securities that contain loans guaranteed by both Fannie Mae and Freddie Mac and to change how the firms determine a home buyerโs representative credit score for the purposes of the ERCF.
