Comment Detail
Date: 07/06/18 First Name: Gordon Last Name: Lane Organization: N/A City: N/A State: N/A Attachment: N/A Number: RIN-2590-AA95 Comment
I would like to point out FHFA and Director Watt, as well as many congressional leaders and housing advocacy and banking groups have come forward with passionate support for a Financial Market Utility structure for the GSEs. I concur. After the passage of Dodd-Frank, capital standards would most appropriately be addressed under Treasury's "Final Rule on Authority to Designate Financial Market Utilities" under the SIFI-declared enterprises designation and capital standards lawfully set in place by the FSOC created by Dodd-Frank.
I would also like to point out that investor complaints that the Amendment 3 Net Worth Sweep was of no benefit to investors is a "red herring" in that investor share prices have actually risen since Amendment 3 was announced, and investors troubled by its provisions had ample time to exit their positions before it was actually implemented in 2013. I would further observe that House Bill No.4171 clearly states in Sectiion 112: "Requires (the Agency)... (2) promote market discipline, by eliminating expectations on the part of shareholders..." under Public Law No. 111-517 passed on 07/21/2010.
I m submitting these comments as a real estate owner and investor in FNMA and FMCC common and junior preferred stocks over a span of several years.