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Comment

After having read the FHFA's Strategic Plan, I realize that for the success of the plan and the changes being taken and needing to be taken would be put in jeopardy by the list you have in "Critical Factors that Affect Achievement of Strategic Goals". Even though I agree that the Common Securitization Platform (CSP) Infrastructure is well needed and does indeed simplify the two agencies offerings of one security (bond) while allowing for the rollover of existing securities to the newer security on a voluntary basis is needed to transition the current system into a better newer system. Now to the my main point as what makes the failure or success of your plan as stated in your plan is that even with all of your changes which have been taken and are in the process of being taken, The FHFA and the Enterprise still have a vulnerable Product, Tool, System while you have taken great steps in improving every aspect of it. I can see that you are all taking this in a direction which I had hoped The FHFA, Freddie and Fannie would go in, as I had stated in my proposal back in 2009 which was made it's way up to Washington, DC and to it's elected officials and agencies . You are stilling missing the mark on what is best and would work best against the peril's from markets and governments outside your control. This is indeed because you still are NOT using the proper tool which would work best for all parties evolved with any aspect of mortgage lending, investing, purchasing, and anything to do with the housing markets as a whole. Two aspects why I know that you are not using or offering the right tool, be it the proper mortgage loan or the proper mortgage security. You are setting up the ground work for being able to do so, but since you are not offering what is best and not properly transforming into what is also the best agency that the FHFA and the Enterprise should be or could be, will still allow you to be vulnerable to that which you have no control over. I appears as almost setting up with an excuse to have when things won't work out when forces from without test the new system you are putting into place. I am against Freddie Mac and Fannie Mae becoming Privatized as agencies again. I also believe that the single Security which should be offered be a Covered Bond. That bond need not be offered via the derivatives market on Wall Street. Yes you may think at it sounds absurd, but history shows you would be mistaken. The people regardless of being an individual or Institutional Investors would be and would purchase the bonds if they are structured and set up properly. The existing banks, and agencies could easily offer these to the public since they could pay much more then any current CD or Bank Savings account. I do have the ideas as to how they should be structured, etc. But before I finish, may I suggest that if the bonds were properly arranged, offered, then the banks and institutions offering them could have any monies which they put as part of the bond, be considered as part of there reserves which they need to keep to comply with regulations of the same. My original proposal and ideas can be seen at www.thefhmsolution.com There you would learn at what is the best tool, which would also work best being offered by transforming Freddie and Fannie into a Covered Bond Banking System. Having the FHFA using the SL-SI NAP Mortgages and Loans tool while offering a true Covered Bond Bank, with out dealing in the Derivatives Market would be what is best for the FHFA, Investors, Homeowners, and our Nation as a whole.
Nelson A Parece
239-699-7897
www.thefhmsolution.com