MBA Coalition Letter on FHFA Suspended Counterparty Program NPR
The American Bankers Association (ABA), Independent Community Bankers of America (ICBA), and Mortgage Bankers Association (MBA) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) proposal to amend the existing Suspended Counterparty Program (SCP). FHFA proposes to expand the categories of “covered misconduct” under which a counterparty (e.g., seller/servicer, vendor) suspension could be based. The new categories include sanctions arising from forms of civil misconduct in connection with, for example, the management or ownership of real property. Additionally, FHFA would be able to issue an immediate suspension order when the misconduct has resulted in debarment, suspension, or limited denial of participation imposed by a federal agency.