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NAFCU lodged concerns about the Federal Housing Finance Agency's planned implementation of the Common Securitization Platform and its potential impact on credit unions in a letter Tuesday from the association's Ann Kossachev.

"Although FHFA's efforts to create a more efficient platform with an ‘open architecture' to support multiple issuer access are commendable, NAFCU and its member credit unions are concerned that the consolidation of securitization programs will make it more difficult for credit unions to sell their loans to Fannie and Freddie," Kossachev wrote.

"NAFCU urges the FHFA to provide safeguards for existing GSE securities held by credit unions so they do not lose their marketability after the introduction of a single security," she continued.

Kossachev urged the FHFA to meet its goal of full fungibility between legacy and new securities and to create a transparent, level playing field that does not favor big banks. She also noted NAFCU's concerns about the overall cost of the CSP and what it might mean for the price of loans sold to government-sponsored enterprises.

The FHFA published a timeline for the CSP in July, which includes the planned implementation of the CSP modules this year. Common Securitizations Solutions, a limited-liability company created by the GSEs, is developing the technology and structures necessary to issue Single Securities beginning in 2018.

NAFCU continues to advocate for housing reform that guarantees access for credit unions to the secondary mortgage market, and fair prices based on loan quality rather than volume.