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Sixth Semiannual Report to the Congress - Federal Housing ...

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members’ access to liquidity during times of economic<br />

stress; create an additional buffer to absorb FHLBank<br />

losses; provide protection on members’ capital<br />

investments; and ensure that the FHLBanks will meet<br />

their consolidated obligations. 71<br />

Selected FHFA and GSE Activities<br />

Over the last six months, there were several significant<br />

FHFA and GSE developments related to: developing<br />

a common securitization infrastructure; creating<br />

exemptions to appraisal requirements for higherpriced<br />

mortgages; assessing the viability of the<br />

enterprises’ multifamily lending businesses in the<br />

absence of a government guarantee; sharing credit risk<br />

with private investors; proposing legislation designed<br />

to replace the activities of the enterprises with a<br />

system more reliant on private capital; and recovering<br />

enterprise losses stemming from alleged violations of<br />

securities laws in the sale of private-label MBS. These<br />

developments and OIG’s efforts in relation to them<br />

are summarized below.<br />

Mortgage Industry Standards<br />

Common Securitization Infrastructure<br />

In April 2013, FHFA issued a progress report<br />

on the development of a common securitization<br />

infrastructure for RMBS. Earlier, in an October 2012<br />

white paper, FHFA called for a two-pronged approach<br />

involving the creation of a new securitization<br />

platform and a model contractual and disclosure<br />

framework. The proposal was designed to contract the<br />

dominant presence of the enterprises in the secondary<br />

mortgage market while simplifying and shrinking<br />

their operations. FHFA received public responses<br />

to the white paper from a broad cross-section of<br />

industry participants and other stakeholders in the<br />

securitization process. 72<br />

Based on this feedback, the update noted progress<br />

on the design, scope, and building of a securitization<br />

platform to perform functions related to data<br />

validation, issuance, disclosures, master servicing,<br />

and bond administration. Additionally, it reported<br />

that efforts to align enterprise contracts and standards<br />

for agency MBS are continuing. The update also<br />

noted that the development of uniform contracts<br />

and standards for credit risk transfer activities is<br />

proceeding according to plan. 73<br />

On August 22, 2013, OIG issued to FHFA a report<br />

assessing risks and fraud threats in the securitization<br />

infrastructure under development and recommending<br />

countermeasures for potential threats. Because<br />

information in this report could be used to exploit<br />

vulnerabilities and circumvent recommended<br />

countermeasures, it has not been released publicly.<br />

Appraisal Requirements for Higher-Priced<br />

Mortgages<br />

In July 2013, six federal financial regulatory agencies<br />

issued a proposed rule creating three exemptions to<br />

appraisal requirements for higher-priced mortgage<br />

loans. In January, the agencies had issued a rule<br />

requiring creditors making higher-priced mortgage<br />

loans to use a licensed or certified appraiser to prepare<br />

a written appraisal report based on a physical visit<br />

to the interior of the property. Loans are considered<br />

higher priced if they are secured by a consumer’s home<br />

and have interest rates above a certain threshold. The<br />

July 2013 proposed rule exempts from the appraisal<br />

requirements loans of $25,000 or less, certain<br />

“streamlined” refinancings, and certain loans secured<br />

by manufactured housing. 74<br />

Mortgage Transactions<br />

Multifamily Housing<br />

In May 2013, FHFA released reports from the<br />

enterprises assessing the potential viability of their<br />

48 Federal Housing Finance Agency Office of Inspector General

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