September 18, 2023

Joint Letter on Suspended Counterparty Program Proposal

The American Bankers Association1 (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.