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NAFCU Regulatory Affairs Counsel Alicia Nealon underscored the importance to credit unions of access to the secondary market, fair pricing and an efficient securitization platform in a letter Monday to the Federal Housing Finance Agency on its 2015-19 strategic plan.

FHFA's goals as regulator of the Federal Home Loan Bank System and conservator of the government-sponsored enterprises Fannie Mae and Freddie Mac focus on ensuring their safety and soundness, promoting liquidity and access to the secondary mortgage market, and building new infrastructure.

"As NAFCU has stated many times, in order to ensure equitable and fair access to the secondary housing market for credit unions, it is critical that mortgage-backed securities have a government guarantee," Nealon wrote. "NAFCU and our members strongly believe that government guarantee of the principal and interest, which carries the full faith and credit of the U.S. government of the securities, is needed in order to ensure that all small financial institutions have access to liquidity, especially in market downturns."

Nealon also urged the agency to focus on fair pricing based on loan quality rather than volume.

Nealon also expressed NAFCU's support for a strong FHLB system, and for a more efficient and standardized securitization platform. Nealon said the association would submit separate comments for the agency's request for input on the proposed Single Security Structure.