“Independent mortgage banks (IMBs) play a crucial role in the economy and in the lives of millions of Americans by responsibly providing mortgages to qualified borrowers, including low- and moderate-income, minority, and first-time homebuyers. They also provide liquidity in the mortgage servicing rights (MSR) market and spur competition and innovation across the housing market, which ultimately helps borrowers. We appreciate that the FSOC report recognizes these important facts, and we believe it calls for policies that strengthen the sector and deepen overall market liquidity, not simply force market share away from IMBs.

"MBA has been working with federal and state regulators, Ginnie Mae, the GSEs, and other counterparties to ensure that IMBs operate within an oversight and counterparty framework that appropriately reflects any potential risks they may pose to the financial system. We look forward to continuing that work. In the end, any proposed policy solutions must be thoughtful and measured to ensure that IMBs can continue to lend to the important market segments they currently serve.”