Submi&ed electronically

Clinton Jones
General Counsel
A7en8on: Comments/ RIN 2590–AB27
Federal Housing Finance Agency
400 Seventh Street SW, Washington, DC 20219.

Re: RIN 2590-AB27 – Enterprise Regulatory Capital Framework Amendments

Dear Mr. Jones,

SIFMA1 submits this le7er in response to the FHFA’s No8ce of Proposed Rulemaking on Enterprise Regulatory Capital Framework Amendments (“NPR”). Our comments are limited to the provisions in the NPR related to capital requirements for commingled security guarantees. 2

1. Summary
SIFMA members con8nue to believe that the fee charged by the Enterprises for commingled security issuance should be eliminated, as it limits investor and other market par8cipant flexibility and breaks a fundamental underpinning of the UMBS construct, which is the fungibility of the two Enterprises’ MBS. We suggest two ways to achieve this: (1) eliminate the provisions in the capital rules that drive the commingling fee, or (2) the Enterprises internalize the capital charges.

1 SIFMA is the leading trade associa6on for broker-dealers, investment banks and asset managers opera6ng in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legisla6on, regula6on and business policy affec6ng retail and ins6tu6onal investors, equity and fixed income markets and related products and services. We serve as an industry coordina6ng body to promote fair and orderly markets, informed regulatory compliance, and efficient market opera6ons and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Associa6on (GFMA).

2 Federal Housing Finance Agency, Enterprise Regulatory Capital Framework Amendments (February 23, 2023), available here: hWps://www.Yfa.gov/SupervisionRegula6on/Rules/RuleDocuments/ERCF%20NPRM%20for%20Web.pdf