Comment Detail

Comment

NAR supports the FHFA’s efforts to improve the fee setting processes at the Enterprises and to maintain safety and soundness. However, we strongly believe that some of the inputs to the price setting process, in particular changes driven by non-risk related additions to the Enterprise Capital Rule Framework (ECRF), are inefficient, run counter to the Enterprises’ charter duties, and should be eliminated. Given the sharp increase in mortgage rates over the last year, no homebuyers should face higher fees at this time. Furthermore, the FHFA should formally adopt a return on equity (ROE) appropriate for market utilities, a cap and a floor on the utility ROE, explore an explicit guarantee, and must establish a robust and durable process for establishing appropriate returns at the Enterprises during conservatorship and after. Thank you for your consideration.