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PESP supports proposed changes to FHFA’s suspended counterparty program

October 3, 2023

On July 21, 2023 the Federal Housing Finance Agency (FHFA) announced that it was proposing amendments to the existing Suspended Counterparty Program (SCP) regulation. FHFA proposes to expand the categories of covered misconduct on which a suspension could be based to include sanctions arising from certain forms of civil enforcement. The proposed rule would also eliminate the requirement that any final suspension order be preceded by a proposed suspension order, but only when the suspension is based on an administrative sanction.[1]

PESP submitted a comment letter in support of the proposed rule on September 19, 2023, highlighting its usefulness in screening problematic corporate landlords out of financing considerations. As the proposal seeks to amend the definition of “conviction” to include civil judgments and material breaches of contract as constituting misconduct, it could help prevent such landlords from exploiting tenants by capturing non-criminal conduct that would render them ineligible for financing.

Please read PESP’s comment letter here. If you have any questions about the FHFA’s proposed amendments to the Suspended Counterparty Program, please contact PESP’s Policy Director, Chris Noble, at





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