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NAR Coalition Memo to FHFA Regarding Recommendations Regarding the Capital Rule for Fannie Mae and Freddie Mac

Issue Date: February 25, 2020


On February 25, the Center for Responsible Lending, Andrew Davidson & Co., Inc. and NAR sent a letter to FHFA Principal Deputy Director Adolfo Marzol and FHFA Senior Counsel for Policy, Jonathan McKernan. The memorandum suggested recommendations regarding the capital rule for Fannie Mae and Freddie Mac. These suggestions primarily include:
  • The regulation of the GSEs as utilities by limiting their overall ROE to a target band sufficient to attract the necessary private investment capital and
  • Counting guarantee fee income toward total risk-based capital requirements.