SIFMA provides comments to the Federal Housing Finance Agency (FHFA) on the Agency’s October 4, 2012 White Paper, Building a New Infrastructure for the Secondary Mortgage Market (the White Paper).  SIFMA strongly supports efforts of FHFA to preserve and modernize the infrastructure of the government sponsored enterprises (Enterprises), Fannie Mae and Freddie Mac.  SIFMA believes that the FHFA should follow a phased approach to implementing its Strategic Plan, and give priority to the alignment of the operations of the Enterprises. This alignment is important to preserve and enhance the liquidity of the TBA market.  SIFMA recommends the FHFA be more specific about its intentions with regard to a number of the issues to be considered for a model Polling and Servicing Agreement (PSA), and that specific credit investor feedback is then required before such proposals are codified in a model PSA to be used for transactions.