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SIFMA urged the Federal Housing Finance Agency ("FHFA") to strengthen a proposed rule on implementing the uniform mortgage-backed security ("UMBS"). In a comment letter, SIFMA stated it supports the "codification of alignment initiatives" to foster confidence in the "To-Be-Announced" ("TBA") market. SIFMA recommended that the FHFA: enhance the definition of "alignment" by (i) focusing on the subset of mortgage-backed securities that affect TBA pricing and (ii) preventing "material deviations in the key pool characteristics that drive future prepayment activity"; and adopt a final rule that