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  • Comment Detail

  • Date: 12/24/14
    First Name: David
    Last Name: Sims
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA73

  • Comment

    The decision by FHFA to follow the original HERA law of 2008 appears to be a positive step towards comprehensive GSE reform. After all, the HERA bill was intended to provide a framework for reforming the housing market. Funding the trusts is simply FHFA following the law written by Congress. My main concern with this decision is that it is not going to be permanent, given the current financial condition of Fannie Mae and Freddie Mac. The Treasury/FHFA decision to sweep all capital to Treasury in 2012 has created a situation where Fannie and Freddie are crippled. At some point in the future, the GSEs will require a capital cushion to protect against losses. Without capital, the trust fund payments will be suspended. Ending the net worth sweep would allow capital to be rebuilt on the GSE balance sheets and solidify the good work that these companies do for the housing market.