November 10, 2015
FINRA, AGM Financial is a small mortgagee specializing in HUD-insured multifamily mortgages only. Our volume is about $350,000,000 annually. Many of our loans are new construction or substantial rehabilitation loans for affordable housing where the GNMA mortgage-back securities are delivered following each monthly draw. We have recently become interested in servicing our own loans, but the proposed margining rule makes servicing impossible for us. Only large banks will be able to support the infrastructure and the financial obligations required to meet your margining rule. We are somewhat puzzled about what problem you are solving. Failure to deliver a GNMA is so rare as to be almost non-existent.