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On behalf of the American Bankers Association, Housing Policy Council, Independent Community Bankers of America, and U.S. Mortgage Insurers, we are responding to one element of the Federal Housing Finance Agency’s (FHFA) Notice of Proposed Rulemaking (NPR)1 on enhancements to the Enterprise Regulatory Capital Framework (ERCF).
Our members represent a wide range of housing finance stakeholders and GSE counterparties in both the primary and secondary mortgage markets, including lenders, servicers, and mortgage insurers.