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VA Insured Cash-Out Home Refinance Loans

Summary

SIFMA submitted comments to Department of Veterans Affairs regarding the interim final rules RIN 2900-AQ42, Loan Guaranty: Revisions to VA Insured Cash-Out Home Refinance Loan. While SIFMA is not an originator of VA loans, we represent the market participants that provide funding for these loans – Ginnie Mae MBS investors and market makers.

As such, we have carefully followed the performance of VA loans and supported the efforts of VA and Ginnie Mae to improve the quality of loan product originated by lenders, obtained by borrowers, and invested in by MBS investors.

PDF

Submitted To

Department of Veterans Affairs

Submitted By

SIFMA

Related Committee(s)

  • Securitization Committee

Date

14

February

2019

Excerpt

Submitted electronically via Regulations.Gov

Director, Regulations Management (00REG)
Department of Veterans Affairs
810 Vermont Avenue NW, Room 1063B
Washington DC, 20420

Re: RIN 2900-AQ42, Loan Guaranty: Revisions to VA Insured Cash-Out Home Refinance Loans

Dear Sir or Madam,

SIFMA1 is grateful for the opportunity to submit these comments regarding the interim final rules referenced in the Re: line above. While SIFMA is not an originator of VA loans, we represent the market participants that provide funding for these loans – Ginnie Mae MBS investors and market makers. As such, we have carefully followed the performance of VA loans and supported the efforts of VA and Ginnie Mae to improve the quality of loan product originated by lenders, obtained by borrowers, and invested in by MBS investors.

SIFMA strongly supported the creation of the VA/Ginnie Mae task force and is grateful for actions taken by Ginnie Mae and VA since that time. MBS investors and VA borrowers have aligned interests regarding these matters. As we noted in a letter to Ginnie Mae supporting the Task Force, we are concerned that the activities of unscrupulous lenders “may negatively impact VA borrowers and believe they have negatively impacted the mutual funds, 401k plans, and other savers invested in Ginnie Mae MBS.” 2

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