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CHLA Comment Letter Raises Small Servicer concerns about FHFA Strategic Plan excerpt

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.