In August of 2022, Fannie Mae proposed a methodology to score their single-family MBS pools using Social data and metrics. In October 2022, both Fannie Mae and Freddie Mac announced that they would align their disclosure practices around the Social Index Score. In response to the GSEs request for comments, SFA sent a letter to both GSEs on January 5, 2023 SFA investor feedback on the Social Index, commending the GSEs for working on enhanced Social disclosures, while also providing the GSEs with the additional type of transparent, granular reporting metrics that provide the bulk of the utility that they rely on to make investing decisions. More work is still needed to provide investors the needed disclosure for ESG Social investing, and SFA is engaging with issuers and investors to identify what those metrics are while, critically, ensuring that the privacy of mortgage borrowers is maintained.

SFA recently submitted an amicus brief to the Third Circuit Appellate in the CFPB v NCSLT case, supporting trusts arguments that passive securitization trusts are not under CFPB Enforcement Authority.