CUNA filed comments with the Federal Housing Finance Agency (FHFA) Tuesday with suggestions on how the housing finance system can ensure access to lenders of all sizes. CUNA filed its comments Tuesday in response to the FHFA’s regulatory review on how its regulations can be made more effective and less burdensome.

“CUNA strongly believes that the housing finance system must ensure that lenders of all sizes have equal access to the secondary mortgage market and the services provided by the government-sponsored entities regulated by the FHFA, including Fannie Mae and Freddie Mac (collectively the Enterprises) and the Federal Home Loan Banks,” the letter reads, adding that CUNA appreciates the FHFA’s voluntary engagement in performing a regulatory review every five years.

CUNA urges FHFA to consider how Fannie and Freddie can facilitate stakeholders’ acquisition of historical information in connected with the validation and approval of new credit score models.

Regarding the Federal Home Loan Bank (FHLBank) System, CUNA:

• Strongly encourages FHFA to support policy changes that would allow all CUSOs to be eligible for membership to FHLBanks,
• Encourages FHFA to reject any kinds of nexus tests that might negatively impact credit unions’ ability to benefit from FHLBank membership or access FHLBank services.
• Supports eliminating the tangible capital requirement when determining whether a new advance can be made to an FHLBank member.