The FHFA OIG’s new paper on Freddie’s IMAGIN pilot program reveals FHFA’s dividing line for when a new GSE product impinges on the primary market – only when the GSE itself is seen as originating a loan through the product. Given that this is barred for them by law, it appears that anything otherwise legal is fair GSE game as long as FHFA likes it. Meanwhile, the report lays out the internal process FHFA follows for designating a “new activity” as a “new product” but still does not reveal the criteria FHFA uses in making the determination.
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