WASHINGTON-- America’s Credit Unions Friday submitted a letter to the Federal Housing Finance Agency (FHFA) commenting on its proposal to rescind and replace the framework of its Enterprise Duty to Serve Underserved Markets regulation.
The letter supports the broad direction of this proposal, as it provides Fannie Mae and Freddie Mac (the GSEs) with greater flexibility to support underserved markets and expand secondary market liquidity for the specialized mortgage products and borrower segments that credit unions frequently serve.
The letter specifically endorses the proposal’s shift away from a rigid menu of prescribed activities that the GSEs must follow toward a more flexible, outcomes-focused approach, in line with America’s Credit Unions’ push for right-sized regulation, the trade group said.
The letter also outlines recommendations to support credit unions’ implementation of the proposal’s new Duty to Serve framework by:
- Expanding the definition of "manufactured homes" to include modular, panelized, and state-code factory-built housing alongside traditional HUD-code homes
- Requiring the GSEs to publish clear and transparent underwriting guidelines for manufactured housing chattel loans within the first year of the Plan's implementation