On April 22, 2022 SFA responded to FHFA’s request for comment on proposed minimum eligibility requirements for GSE seller servicers. SFA applauds these efforts, recognizing that a healthy housing finance system requires appropriate levels of capital and liquidity. In response to the FHFA request for input our members have consistently reported the ability to meet these standards, and—in many cases—are already doing so.

With that in mind, SFA offers some general observations and specific suggestions for how these standards might best be implemented in a way that does not cause undue disruption. These suggestions and observations include:

• Clarifying when FHFA may use discretionary authority above what is required by the minimum standards
• Phasing in implementation of the standards over time
• Potential limited use of near-term mortgage servicing receivables as a source of liquidity
• Procedural suggestions for liquidity buffer draw-down during a stress scenario
• Allowing delegation of the ratings requirement to an approved sub-servicer
• Clarifying outcomes and maintaining confidentiality of stress test results

Again, SFA recognizes the importance of a liquid and well-capitalized housing market system, and looks forward to continuing our dialogue with regulators, stakeholders, and policymakers on this important topic.