In March, CHLA released a comprehensive plan to reform the GSEs. CHLA’s plan is the only plan that puts the interests of non-bank small and mid-sized mortgage bankers first – including formal protections to ensure IMB competitiveness for both cash window and securitization execution. Plan components are:

• FHFA suspension of dividends to build a capital buffer and avoid a Treasury advance.

• FHFA to develop a capital restoration plan for Fannie/Freddie to exit conservatorship.

• A true utility model – excluding Wall Street Banks from obtaining new charters to compete with Fannie and Freddie – and thereby gain control over the origination market.

• Formal small lender protections regarding risk sharing – a prohibition on up-front risk sharing, a ban on volume discounts, and real protections against vertical integration.

• Making recent taxpayer protection reforms permanent – risk sharing, portfolio limits, bans on no doc loans, strong underwriting standards, and a strong regulator (FHFA)