MBA Letter to FHFA on Eligibility Requirements for GSE Servicers

2022 Comment Letters Government Servicing Policy Issue Residential Secondary and Capital Markets
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This April 25 letter responds to a Federal Housing Finance Agency (FHFA) proposal to update capital, liquidity, and net worth requirements for servicers of GSE-backed loans. MBA’s detailed recommendations focus on the aggregate levels of required liquidity, the additional surcharges associated with hedging of mortgage pipelines, and the lack of recognition of committed lines of credit. These MBA recommendations are designed to promote resiliency among servicers while ensuring consumer access to credit is not unduly restricted.