CHLA Comment Letter to Ginnie Mae: Stress Testing is Not Appropriate for Smaller IMB Issuers

CHLA submitted a comment letter to Ginnie Mae, arguing that Ginnie Mae should not stress test smaller IMB issuers, as stress testing would not accurately measure smaller issuer risk, would undermine consumer access to credit, and would increase issuer concentration.  The letter drew heavily from CHLA’s January “Report on Ginnie Mae.”