SIFMA provides comments to the U.S. Department of Housing and Urban Development (HUD) regarding the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (the SAFE Act), Docket No. FR-5271-P-01. SIFMA welcomes HUD’s efforts to enhance consumer protection, improve accountability, and combat fraud by developing baseline licensing standards for mortgage loan originators. SIFMA is concerned that the proposed rule defines the term “loan originator” in a manner that is both overbroad on its face, and beyond the SAFE Act, such that it unnecessarily threatens consumer choice and access to consumer credit.