MBA Responds to FHFA’s Proposed 2026-2028 Housing Goals

The Mortgage Bankers Association sent a comment letter to the Federal Housing Finance Agency in response to the agency’s proposed rule on its 2026-2028 housing goals for Fannie Mae and Freddie Mac, the GSEs.

The letter noted MBA appreciates FHFA’s efforts to align the housing goals with current market conditions and maintain focus on affordability and liquidity.

A few of MBA’s recommendations include:

• MBA supports FHFA’s intent to balance affordable housing support with broader market liquidity and reduce harmful competitive behaviors among the GSEs. However, MBA recommends FHFA revisit the single-family low-income refinance goal (currently 26%), noting that it may be unrealistic given rate volatility and potential increases in high-balance lending volume. Without measurement buffers, market shifts could make this goal unattainable.

• MBA strongly encourages FHFA to retain measurement buffers removed in the proposal. Buffers help mitigate market distortions and retroactive adjustments when goals diverge from actual conditions. Without them, rapid market changes could produce unintended consequences for lenders and borrowers.

• FHFA should work with stakeholders to explore methods such as cash-flow underwriting and rental payment history integration to sustainably increase affordable lending. Greater transparency into the overall addressable market for such loans would support more balanced policy design.