November 10, 2015
To whom it may concern:
Please re-consider the inclusion of the GNMA Multi-family Mortgaged Backed Securities in your proposed regulation of forward settling securities. The proposed rule would require significant shifts in the market that would be severely detrimental to the Multi-family markets in the name of “fixing” a problem that simply does not exist.
The nature of the GNMA multi-family market consists of a single, pre-approved, fully identified loan in single security. This loan has already been fully vetted and approved through the FHA program at HUD. The risks of non-delivery are exponentially different than those in the single family market, which this rule primarily targets. In the 35 year history of our company, we have NEVER had a non-delivery of a GNMA multi-family security.
The adoption of these rules, we significantly impact the market and could potentially lead to smaller issuers being forced from the market, while not improving the viability of the market. The loss of these players and the likely increase in capital allocations and costs, will be extremely negative, while achieving no public purpose goals.
I strongly urge you to consider the appropriate exemption of the GNMA Multi-family mortgage backed securities from this proposed rule.
Thank you for your consideration.