In a letter to FHFA, CHLA makes a series of recommendations to protect smaller IMBs by revising proposed new financial requirements for Fannie/Freddie seller/servicers – including scrapping the 2% TBA hedging liquidity requirement for smaller IMBs and creating an FHLB advance program for IMBs.

While a CHLA comment letter on FHFA’s Draft 2022-2026 Strategic Plan generally praised the Plan’s commitment to access to mortgage credit, CHLA raised concerns about an excerpt from the plan hinting that FHFA was considering using direct exam authority over non-bank servicers. The CHLA letter concluded this is neither necessary or warranted – offering detailed points to back up that conclusion.

A Mortgage Note profile of the CHLA highlights CHLA efforts to educate federal policy makers on IMBs, particularly the key role smaller IMBs play – citing recent advocacy to protect them from regulatory creep and to temper recently announced Fannie/Freddie fee hikes

In a letter to CFPB Director Rohit Chopra, CHLA called attention to the Dodd-Frank requirement for the CFPB to tier regulation of IMBs by size, volume, and extent and state regulation – calling on exemptions from exams for smaller IMBs and a formal policy that smaller IMBs would have the opportunity to correct compliance problems before being hit with fines and other enforcement actions