Fannie Mae and Freddie Mac UMBS Pooling Practices

Mr. Robert Fishman
Deputy Director
Division of Conservatorship
Federal Housing Finance Agency (FHFA) 400 7th Street SW, 8th Floor Washington, DC 20219

Re: Request for Input—Fannie Mae and Freddie Mac UMBS Pooling Practices

Dear Deputy Director Fishman:

The Milken Institute Center for Financial Markets appreciates the opportunity to provide input on FHFA’s Request for Input (RFI) on Fannie Mae and Freddie Mac Uniform Mortgage-Backed Security (UMBS) Pooling Practices.

The Milken Institute is a nonprofit, nonpartisan tank catalyzing practical solutions to global challenges by connecting resources to those who need them. The Milken Institute Center for Financial Markets (CFM)3 conducts research and constructs programs designed to facilitate the smooth and efficient operation of financial markets—to help ensure that they are fair and available to those who need them when they need them.

The Fannie Mae and Freddie Mac (each an Agency or GSE4) “To Be Announced” (TBA) securities market is the backbone of conventional mortgage lending, allowing efficient origination and investment in 30-year fixed-rate conventional mortgage loans. FHFA should move carefully in making changes to the UMBS that might have unintended negative consequences on the TBA market.

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