Round Three
We continue our analysis of key comment letters pending a wrap-up and outlook to come. A key consideration then will be the extent to which critiques on grounds such as the need for an explicit USG guarantee and lost GSE market share will actually persuade FHFA to hold its ground to achieve the Administration’s goal – i.e., reduced GSE market share. We’ll also assess where the combination of united opposition, technical observations, and political reality could lead FHFA to bend, at least a bit.

GSE-090220.pdf