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  • Comment Detail

  • Date: 08/09/23
    First Name: Michael
    Last Name: Garrett
    Email: MGarrett@cacu.com
    Organization Type: other
    Organization: CommunityAmerica Credit Union
  • Comment

    Allow Seasoned Mortgage Bulk Sales - The 6 sale window maximum is too restrictive. The ability to sell more seasoned mortgages into the GSE's in bulk was historically a valuable tool for financial institutions. CommunityAmerica utilized this ability on multiple occasions over the years following the Great Financial Crisis, and found it invaluable to managing liquidity and risk on the balance sheet. Bringing back seasoned bulk sales would assist in solidifying the strength of the banking systems by offering better options for financial institutions to manage their balance sheets.