SFA Comparison of FHFA’s Final ECF To Proposed ECF

On November 18, 2020 FHFA Announced the Final Rule on the Enterprise Capital Framework (ECF), which came after SFA submitted a response on the Proposed ECF. SFA compared the Proposed ECF against the Final ECF, noting that while FHFA had made modest changes pursuant to SFA feedback, it failed to address threshold questions—particularly as it relates to releasing the GSEs from conservatorship and the viability of the Enterprises’ Credit Risk Transfer programs. Other foundational questions that remain unresolved include the existence of a government guaranty on legacy and new-issue Agency securities, the impact on availability of credit through all phases of the credit cycle, and whether U.S. depository banks, foreign central banks, and the Federal Reserve would be willing or even able to continue to purchase Agency securities in the future.”