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Comment

The GSE Guaranty Fees are not only NOT too low, they are in fact, TOO HIGH. I applaud Director Watt's decision to suspend implementation of his predecessor's plan to hike G-Fees yet again, pending a careful review. The fact is, recent vintages of GSE-backed mortgage loans have shown stellar credit performance, at or near best-ever levels. At teh same time, both of teh Agencies have become enormously profitable. It is most likely difficult for most members of the public, and perhaps even many within industry and/or regulatory and policy-making roles to truly understand the negative impact of needlessly high G-Fees. This is because Fed actions have effectively kept retail mortgage loan rates at attractive levels for the past several years. Nevertheless, many mortgage buyers are arguably paying too much for their mortgages, due to elevated G-Fee levels. With the implementation of QM this year, maximum DTI ratios have come under strong downward pressure; this in combination with mortgage rates that are 10-25 basis points higher than they need to be has effectively priced a cohort of otherwise qualified home buyers out of the market, thereby depressing economic activity. A much larger cohort of American homeowners who can still qualify for loans are nevertheless paying more than they need to in mortgage interest, thereby reducing their savings and/or spending capacity, again to the detriment of the larger economy. For these reasons, I urge you to consider ROLLING BACK the G-Fees by 10-25 basis points. Thank you.