#Freddie

18 07, 2022

m071822

2023-01-06T14:55:15-05:00July 18th, 2022|6- Client Memo|

A Pragmatic Vision of a Purposeful Home Loan Bank System

Although a new paper by former FRB Gov. Tarullo and Fed staffers on the FHLB stirred considerable consternation across the Federal Home Loan Bank System, it’s a crushing and persuasive critique of a giant GSE that has long preferred to go unnoticed.  That’s not unreasonable since the System has evolved from an essential small-bank funding source for mortgages into a taxpayer-subsidized capital-markets investment option.  When public wealth is not allocated for public welfare, resources are misallocated and market integrity is compromised.  But, unless the Home Loan Banks blow themselves up, they are here to stay.  Thus, the policy challenge is not how to abolish them, but how best to redirect an established funding channel back to servicing the public good.  Traditional single-family mortgages don’t need the Banks anymore, but much else does.

m071822.pdf

18 07, 2022

Karen Petrou: A Pragmatic Vision of a Purposeful Home Loan Bank System

2023-01-06T14:56:42-05:00July 18th, 2022|The Vault|

Although a new paper by former FRB Gov. Tarullo and Fed staffers on the FHLB stirred considerable consternation across the Federal Home Loan Bank System, it’s a crushing and persuasive critique of a giant GSE that has long preferred to go unnoticed.  That’s not unreasonable since the System has evolved from an essential small-bank funding source for mortgages into a taxpayer-subsidized capital-markets investment option.  When public wealth is not allocated for public welfare, resources are misallocated and market integrity is compromised.  But, unless the Home Loan Banks blow themselves up, they are here to stay.  Thus, the policy challenge is not how to abolish them, but how best to redirect an established funding channel back to servicing the public good.  Traditional single-family mortgages don’t need the Banks anymore, but much else does.

The paper’s criteria for considering taxpayer subsidies are a very helpful guide for moving forward and thus worth quoting at length:

“There is, of course, nothing inherently wrong with government subsidies. But subsidies should meet two conditions if they are to be sound public policy. First, they must be shown to be correctives for identified market failures or instruments of targeted redistribution policies.  Second, there must be governance mechanisms to ensure that the subsidies are used to achieve the ends specified by the legislature or regulator, and not for other purposes.”

I suspect the authors would agree with a third point:  if a credible, forward-looking case for the subsidy cannot be made by virtue of demonstrable public benefits …

15 07, 2022

Al071822

2023-01-06T14:59:56-05:00July 15th, 2022|3- This Week|

Home in the OK Corral

On Wednesday, FHFA Director Thompson will come before HFSC for what will be an important discussion of housing policy under the newly-confirmed director if Members of Congress allow policy substance to supersede political battles over who is responsible for inflation for which dastardly reason.  In hopes of substance, we’ll monitor the hearing and provide you quickly with an in-depth analysis.

Al071822.pdf

23 06, 2022

GSE-062322

2023-01-25T15:52:27-05:00June 23rd, 2022|4- GSE Activity Report|

No Oops re UMBS

Following a sharp critique of GSE capital standards earlier today from the Urban Institute, FHFA Director Thompson today acknowledged Fannie and Freddie’s new 50 bps fees when one of the GSEs guarantees the other’s collateral for UMBS purposes.  The Urban Institute paper argued that these fees properly reflect the capital cost of the rules’ weightings related to these cross-guarantees, going on to say that the fees are likely over time to reduce investor appetite for Freddie Mac securities and thus undermine the UMBS construct and its broader benefits.

GSE-062322.pdf

9 06, 2022

FedFin on: Equitable Endeavors

2023-01-27T15:57:10-05:00June 9th, 2022|The Vault|

When Sandra Thompson earlier this year enunciated a new equitable-finance mission, we forecast that Fannie and Freddie would undertake an array of new activities that significantly expand their footprint along with their equity and equality impact.  As anticipated, the plans announced yesterday by Fannie and Freddie go beyond FHFA’s reiterated mission statement earlier this week, mirroring in some ways the banking agencies’ broad view of CRA as a community-development and racial-equity instrument as well as the boost to LMI housing on which attention long focused.  But, for all the public-good creds these plans engender, several will doubtless promote market angst as the GSEs launch pilots that tread heavily on MI, title-insurer, and servicer toes.

The full report is available to subscription clients. To find out how you can sign up for the service, click here.…

9 06, 2022

GSE-060922

2023-01-27T15:57:01-05:00June 9th, 2022|4- GSE Activity Report|

Equitable Endeavors

When Sandra Thompson earlier this year enunciated a new equitable-finance mission, we forecast that Fannie and Freddie would undertake an array of new activities that significantly expand their footprint along with their equity and equality impact.  As anticipated, the plans announced yesterday by Fannie and Freddie go beyond FHFA’s reiterated mission statement earlier this week, mirroring in some ways the banking agencies’ broad view of CRA as a community-development and racial-equity instrument as well as the boost to LMI housing on which attention long focused.  But, for all the public-good creds these plans engender, several will doubtless promote market angst as the GSEs launch pilots that tread heavily on MI, title-insurer, and servicer toes.

GSE-060922.pdf

7 06, 2022

GSE-060722

2023-02-10T15:52:15-05:00June 7th, 2022|4- GSE Activity Report|

Mission Possible

FHFA released its first-ever report on the extent to which Fannie, Freddie, and the FHLBs meet their statutory mission.  Although the report does address other mission issues via a brief discussion of fair lending and the GSE-conservatorship scorecard, its focus is almost exclusively on housing.  Fannie and Freddie meet their goals via a series of programs described at some length in the report.  While the FHLBs have not yet had their housing and community-investment activities fully approved, the report suggests that they will soon enjoy like-kind approbation.  We expect no policy, program, or political changes in response to the report, although it’s sure to come up if Congress turns to considering the GSEs any time soon.

GSE-060722.pdf

27 05, 2022

GSE-052722

2023-02-21T13:34:07-05:00May 27th, 2022|4- GSE Activity Report|

Now You Know

FHFA has finalized its October proposal to create a new qualitative capital and governance  disclosure regime, going well beyond the disclosures initially mandated in the final capital rule to instill market discipline long associated with private companies, not conservatorships.  FHFA’s goal is to ready Fannie and Freddie for a return to private markets without implicit-guarantee guardrails, but the chances of that in the near future seem small.  Minor pricing differences on debt and derivatives are thus the new rule’s most likely result.

GSE-052722.pdf

16 05, 2022

Daily051622

2023-02-21T15:00:14-05:00May 16th, 2022|2- Daily Briefing|

When the Fed Goes from Whatever-It-Takes to Anything-We-Can-Think-Of
On Thursday, the Washington Post included an article on all the ways in which inflation hurts middle-income families, the acute shortage of baby formula, and the cooking-oil shortage’s cost impact in places ranging from a D.C. shop selling doughnuts to sub-Saharan Africa.  Other articles chronicled stablecoins’ instability even as stock markets wobbled precariously above going so deeply into correction that investors are not just chastened, but also cudgeled.

CFPB Warns Wayward Mortgage Servicers
The CFPB released a report today showing that only a relatively small number of homeowners – about 330,000 – are struggling with mortgage modification after forbearance ended late last year.

White House Recasts Old Housing Policy for New Political Problem
Reflecting continuing political pressure from rising costs, the White House this morning announced what it calls new programs to increase housing supply in ways it says would lower costs.  Little in the plan is new, with much of it recounting ongoing work to, for example, reduce NPL sales to investors in favor of those to owner-occupants and community groups.

CFPB Takes to Circulars to Extend, Expand Jurisdiction
Following up on his announcement (see Client Report CONSUMER40) that the CFPB plans to rewrite consumer-protection standards promulgated by other agencies, Director Chopra today took the unusual step of describing processes by which the CFPB will determine key enforcement criteria via circulars to promote enforcement consistency and fair competition.

Daily051622.pdf

15 04, 2022

GSE-041522

2023-03-02T11:07:28-05:00April 15th, 2022|4- GSE Activity Report|

Plan B

Cementing her very different vision of Fannie and Freddie, Acting Director Thompson has now finalized a new strategic plan for the FHFA emphasizing the importance of both equitable and sustainable housing finance.  As anticipated, the final plan requires more of Fannie, Freddie, and the FHLBs not only on the new equity mission, but also on climate-risk mitigation.  The only major difference from the proposed and the final plan is an expression of somewhat greater confidence from FHFA that it can go after third-party counterparties if it wants to.

GSE-041522.pdf

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