We have reviewed the comment letters filed with FHFA on its proposal detailing how a GSE – FHLBs included — could be put into conservatorship, receivership or bridge status. Our assessment of the proposal highlighted its major impact on the FHLBs – some of which are far from robust – and the Home Loan Banks have clearly taken this to heart. Their letter howls about the potential process proposed by FHFA. Other comments focus on preserving individual interests in the event a GSE is taken from conservatorship to liquidation, with Members of Congress weighing in on behalf of union pension interests that have outstanding lawsuits against the GSEs.

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