CRL submitted a comment on the Federal Housing Finance Agency’s Single Family Pricing Framework arguing that the FHFA should take three steps:
- Revisit and revise the Enterprise Regulatory Capital Framework, which currently imposes excessive capital requirements on the GSEs;
- Continue the forward momentum of its recent elimination of LLPA’s for first-time homebuyers and certain affordable housing products by expanding its efforts to reach minority borrowers with increased marketing outreach, special purpose credit programs, etc., and
- Eliminate upfront guarantee fees for first-generation homeowners, single, head-of-household borrowers, and small mortgage borrowers.