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  • Comment Detail

  • Date: 10/16/14
    First Name: Simeon
    Last Name: Slavchev
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA65

  • Comment

    To Whom it may concern,
    The Affordable Housing Goals of both enterprises are something that benefits the whole country, the national economy and the individual families involved. However given the Third Amendment to the Purchase Agreement between the GSEs and the United States Treasury implemented in 2012 having these goals and eventually increasing their percentage of total purchases is irresponsible and completely detrimental to the nation as a whole. The Third Amendment to the Purchase Agreement specifies that by 2018 both enterprises will have zero capital which put us the taxpayers at immediate risk of any losses incurred by the two enterprises. The probability of the GSEs incurring losses is substantial since the loans under the Affordable Housing Goals are made to moderate and low income families. Historically these loans are the ones with the highest default rates of all loans acquired by the enterprises. In the event we have even a small downturn in the hosing market the lack of appropriate levels of capital will cause the enterprises to draw additional funds from the United States Treasury. This is something that politicians from both sides of the isle have said is unacceptable. The Affordable Housing Goals need to be transferred and administered by the FHA which is a government entity with sufficient capital buffers.