NAHREP issues joint comment letter to FHFA on Enterprise Regulatory Capital Framework

In a joint comment letter submitted to FHFA, NAHREP and a coalition of industry and consumer groups urge the agency to reconsider the proposed enterprise capital rule. While the coalition appreciates FHFA’s attempt to provide a more standardized level of risk-based pricing, the capital requirement as proposed is far too high. As the GSEs are not banks, having bank-like capital requirement will unnecessarily increase costs, reduce credit availability and disproportionately impact borrowers of color. Furthermore, the rule would not meet its goal of reducing risk to the overall housing finance system, but rather redistribute and concentrate it.