On December 3, the Missouri Credit Union Association (MCUA) filed a comment letter with the Federal Housing Finance Agency (FHFA) regarding an agency white paper entitled “Building a New Infrastructure for the Secondary Mortgage Market.” As the FHFA moves forward with completing its design of a new infrastructure for the secondary mortgage market, MCUA urged the agency to take steps to ensure that the impact of a new infrastructure on small lenders such as credit unions is positive for them and their members. As noted in the letter, it is imperative that credit unions continue to maintain access to the secondary mortgage market.
Additionally, MCUA urged the FHFA to allow issuers and primary servicers to access the platform directly through any new infrastructure that may be developed. Inputting data directly, rather than having to pass such information along to primary servicers, would be beneficial for smaller financial institutions.
In the letter, MCUA also called upon the agency to approach the definitions within any new infrastructure very carefully. Depending on how certain terms are defined within either the infrastructure, the platform, or a standardized Pooling and Servicing Agreement (PSA) could have far-reaching implications for small lenders such as credit unions.