Skip to main content

  • Comment Detail

  • Date: 06/28/18
    First Name: Ronald
    Last Name: Tankersley
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA95

  • Comment

    Based on historic operations and forensic accounting it has been proven beyond doubt that neither Fannie nor Freddie needed government intervention or capital at the time of the conservatorship or subsequently. Cash flow for each remained positive through the entire term of the conservatorship. Losses and Treasury draws can be attributed primarily to accounting estimations recorded at the direction of the previous FHFA Director and the Treasury Department. Consequently actual loss data would indicate that capital levels for portfolio loans held as investments were adequate prior to the conservatorship. Proposed capital levels in excess of 2.0% to 2.5 % should not be needed so long as prudent underwriting standards; (1) LTV and (2) borrower ability to pay are observed.