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NAFCU's Ann Kossachev told the Federal Housing Finance Agency on Friday that while the association supports the government-sponsored enterprises' plans to serve underserved markets, the association has concerns regarding their launch into chattel loan pilot programs, among other initiatives.

Under the FHFA's final duty-to-serve rule, Fannie Mae and Freddie Mac are required to adopt plans to improve the distribution and availability of mortgage financing for residential properties that serve very low-, low- and moderate-income families in the three specified underserved markets. These plans will become effective January 2018.

Kossachev, NAFCU's regulatory affairs counsel, requested that the FHFA closely evaluate the GSEs proposals with regard to the regulatory activities laid out in their plans – including chattel lending and the purchasing of affordable housing and rural housing loans from small financial institutions – to ensure that "credit unions' vital role in these markets is recognized and their access to the secondary mortgage market is expanded."

Kossachev urged that the GSEs "proceed in a slow and steady manner with regard to the chattel loan market."

Relative to affordable housing preservation, she added that NAFCU requests that the FHFA "critically evaluate the GSEs Plans with respect to small multifamily affordable loans from financial entities with $10 billion or less in assets." Kossachev also explained NAFCU's concerns regarding the number of rural housing loans the GSEs plan to purchase.

"The ultimate goal of the GSEs should be to help provide liquidity to credit unions in these communities and figure out creative solutions to create economies of scale to sell mortgage-backed securities in this market for loans on both single and multi-family homes," she wrote.