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SFA Submits Response to FHFA’s NPR on the ERCF Amendment

article by Structured Finance Association

On May 12, 2023, the Structured Finance Association submitted a response to the Federal Housing Finance Agency on their Notice of Proposed Rulemaking on the Enterprise Regulatory Capital Framework (ERCF) Amendment. SFA supports the proposed reduction of the risk-based capital charge on commingled securities from a 20% risk weight to a 5% risk weight, as well as reducing the credit conversion factors, which are directionally in line with SFA’s previous advocacy efforts. SFA encourages FHFA to continue to monitor UMBS, as well as other developments related to Enterprise capital.