Freddie Mac and Fannie Mae

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					                              Freddie Mac and Fannie Mae
                                An Exit Strategy for the Taxpayer
                                                     by Arnold Kling




No. 106                                                                                             September 8, 2008

                                                  Executive Summary
             The Fannie Mae-Freddie Mac crisis may have              Regulators should contemplate freezing the
         been the most avoidable financial crisis in histo-       mortgage purchase activities of the GSEs while
         ry. Economists have long complained that the             at the same time loosening the capital require-
         risks posed by the government-sponsored enter-           ments for banks to hold low-risk mortgages.
         prises were large relative to any social benefits.       The result would almost surely be an industry
             We now realize that the overall policy of pro-       much less concentrated than the current duop-
         moting home ownership was carried to excess.             oly. A housing finance system that does not rely
         Even taking as given the goal of expanding home          so heavily on Freddie Mac and Fannie Mae will
         ownership, the public policy case for subsidizing        be more robust.
         mortgage finance was weak. The case for using               We have to assume that sooner or later some
         the GSEs as a vehicle to subsidize mortgage              of the institutions involved in mortgage finance
         finance was weaker still. The GSE structure serves       will fail. The policy should be to promote a hous-
         to privatize profits and socialize losses. And even      ing finance system where mortgage risk is spread
         if one thought that home ownership was worth             among dozens of institutions. That way, the fail-
         encouraging, mortgage debt was worth subsidiz-           ure of some firms can be resolved through merg-
         ing, and the GSE structure was viable, allowing          ers and orderly restructuring, without exposing
         the GSEs to assume a dominant role in mortgage           the financial system to the sort of catastrophic
         finance was a mistake. The larger they grew, the         risk that is represented by Fannie Mae and
         more precarious our financial markets became.            Freddie Mac.



 Arnold Kling is an adjunct scholar with the Cato Institute. After receiving his Ph.D. in economics from the Massachusetts
 Institute of Technology, he worked as an economist at the Federal Reserve Board for six years and then at Freddie Mac for about
 10 years in the 1980s and 1990s. He blogs at econlog.econlib.org.

       Cato Institute • 1000 Massachusetts Avenue, N.W. • Washington, D.C. 20001 • (202) 842-0200
The GSE crisis                                                                mark notes in 2000 and triple what it
may have been                   Introduction                                  paid in June 2006.1

      the most         The United States Congress has a genius             The story goes on to note that the market was
     avoidable     for creating government programs that are               treating the debt of Fannie Mae and Freddie
                   difficult to terminate. For example, with               Mac as if it were rated A2 by Moody’s. The
financial crisis   Social Security and Medicare, there is no way           actual rating on the debt is AAA, and histori-
    in history.    to cut taxes on current workers without                 cally investors priced it that way. But, alarmed
                   threatening the benefits of current recipients.         by large losses and thin capital shields at the
                   There is no pool of accumulated assets that             GSEs, investors began to contemplate the risk
                   can be used to pay beneficiaries, the myth of           of a GSE default.
                   trust-fund accounting notwithstanding.                      Once this risk was priced into their debt
                       Similarly, the mortgage market duopoly of           instruments, the two firms’ borrowing costs
                   Freddie Mac and Fannie Mae, which five years            soared, placing them in jeopardy.
                   ago held over half of the outstanding mort-                 The loss of confidence in the GSEs, which
                   gage debt in the United States, is difficult to         spread to the stock market, could quickly have
                   terminate. They cannot be merged with other             driven them into bankruptcy. Had the Treasury
                   financial institutions, because those other             and Congress failed to act, a GSE default would
                   institutions lack the special borrowing privi-          have become a self-fulfilling prophecy. The con-
                   leges that the government-sponsored enter-              sequence of the hastily passed late-summer leg-
                   prises (GSEs) enjoy.                                    islation is that if the housing market gets worse
                       In fact, the reaction of Congress to the cri-       or if it turns out that the less-than-transparent
                   sis created by subprime mortgage defaults was           portfolios of the GSEs contain hidden weak-
                   to expand the role of the GSEs in mortgage              nesses, taxpayers could be liable for tens of bil-
                   finance. Each mortgage purchased by one of              lions of dollars in shortfalls.
                   the GSEs would have been limited to no more                 In this briefing paper, I will suggest ways
                   than $417,000, except for emergency legisla-            that Congress could gradually extricate hous-
                   tion last December raising the limit to                 ing policy from its dependence on the GSEs.
                   $729,750. Indeed, in the first quarter of this          While it may be too late to insulate taxpayers
                   year, the GSEs funded 70 percent of new mort-           from the risks embedded in the GSEs’ current
                   gages.                                                  portfolios, it is possible to shrink the GSEs
                       Early in July, there was an abrupt collision        without significantly damaging the housing
                   between congressional intent and market                 market.
                   reality. On July 9, Bloomberg reported that:                Three questions are worth examining:

                      Fannie Mae paid a record yield over                     1. What policies might have prevented the
                      benchmark rates on $3 billion of two-                      crisis?
                      year notes amid concern that the U.S.                   2. How does the recently passed legisla-
                      mortgage-finance company doesn’t                           tion deepen government involvement
                      have enough capital to weather the                         in housing finance?
                      biggest housing slump since the Great                   3. Going forward, how could government
                      Depression.                                                extricate itself and the GSEs from a dom-
                         The 3.25 percent benchmark notes                        inant role in the housing market?
                      priced to yield 3.27 percent, or 74 basis
                      points more than comparable U.S.
                      Treasuries, the Washington-based com-                       An Avoidable Crisis
                      pany said today in an e-mailed state-
                      ment. That’s the biggest spread since                   The GSE crisis may have been the most
                      Fannie Mae first sold two-year bench-                avoidable financial crisis in history. Economists



                                                                       2
                        How Do the GSEs Work?
    The GSEs operate in what is called the secondary mortgage market. That is, they
purchase mortgage loans from other sources. As a home buyer, you cannot obtain a
mortgage directly from Freddie Mac or Fannie Mae. Instead, you obtain your loan from
someone in the primary mortgage market (a bank or a mortgage banker), and that
lender sells the loan to one of the GSEs. The GSEs then combine your mortgage loan
with similar loans into what are called mortgage pools. These pools are formed into
pass-through securities, meaning that the principal and interest on the mortgages in
the pool are passed through to investors in the securities. The GSEs can either sell the
mortgage-backed securities to other investors or retain the securities for themselves. In
the 1990’s, Freddie gradually shifted from a strategy of selling most of its securities to
a strategy of retaining most of its securities. Fannie has always predominantly held its
securities in its portfolio. Whether it retains or sells the security, the GSE bears the
default risk of the mortgages, which is the source of the recent crisis.
    The GSEs take responsibility for ensuring that all the principal and interest on the
                                                                                             Economists have
underlying mortgages is returned to investors, even if the mortgage borrowers them-          long complained
selves default on their loans. If a borrower defaults, the loan is removed from the pool.    that the risks
The GSE pays the full principal amount to the holders of the security and then recov-
ers what it can from a foreclosure sale. When this happens, the GSE typically absorbs a      posed by the GSEs
loss of about half the outstanding principal on the loan.                                    were large relative
    The GSEs charge a fee, known as a guarantee fee, that on average is sufficient to cov-
er their losses and provide a profit. If the primary lender offers you a mortgage loan at
                                                                                             to any social
an interest rate of 6.75 percent, the GSE may put the loan into a security that pays 6.50    benefits.
percent. The remaining 0.25 percent is retained by the GSE as its guarantee fee.
    GSEs earn profits in two ways. First, the guarantee fee is typically larger than what
is needed to cover the cost of mortgage defaults. This is called their mortgage insurance
business, because the GSEs are providing insurance to investors against mortgage
defaults. Second, when the GSEs retain securities rather than selling them, they earn a
financing profit. If a GSE retains a security that yields 6.50 percent and it can finance
that security by issuing debt that costs only 6.25 percent, then the GSE earns a spread
of 0.25 percent. This is called the portfolio lending business, because the GSEs are man-
aging a portfolio of investments in mortgage securities.
    In both the mortgage insurance business and the portfolio lending business, the
GSEs have two important advantages. These advantages are a lower risk premium and
lower capital requirements.
    In the capital markets, U.S. Treasury debt is considered risk-free, and every other
borrower pays a higher interest rate than the Treasury. That difference is called a risk
premium. The greater the uncertainty about the borrower’s financial condition, the
higher the risk premium. Because investors believed that the GSEs would not be
allowed to fail, until very recently the risk premium on GSE debt was very low.
    The second advantage that the GSEs enjoy is low capital requirements. When banks
engage in the mortgage insurance business or the portfolio lending business, they are
required by their regulators to put more of their shareholders’ funds at risk than the
GSEs are. This makes it difficult for banks to compete with GSEs.




                                            3
                      have long complained that the risks posed by                 Regulators corrected some accounting
                      the GSEs were large relative to any social bene-             flaws that had allowed insolvent institu-
                      fits. But the GSEs have used political clout to              tions to continue expanding. Regulators
                      beat back attempts to limit their growth.                    also made changes to the incentive struc-
                          The growth of the GSEs took place in sev-                ture of deposit insurance, forcing riskier
                      eral stages. An approximate timeline of events               banks to pay higher premiums.
                      is as follows:                                             • In the early 1980s, as the S&Ls were falter-
                                                                                   ing, Fannie Mae was losing a million dol-
                         • In 1938 the Federal National Mortgage                   lars a day. Fannie’s problem was rising
                           Association (ultimately nicknamed Fan-                  interest rates and a portfolio of long-term
                           nie Mae) was formed as a government                     mortgages financed in part by short-term
                           agency to try to fill some of the gap in the            debt. However, Fannie Mae kept growing
                           mortgage lending industry left by the                   as its S&L competitors fell by the wayside,
                           wave of bank defaults in the Great                      and when interest rates stabilized and
                           Depression.                                             came down, Fannie Mae became highly
                         • In 1968, in part to get Fannie Mae’s lia-               profitable.
                           bilities off the government balance sheet,            • Also in the early 1980s both Freddie
                           Fannie Mae was spun off to private                      Mac and Fannie Mae fed off the carcass-
                           investors.                                              es of the thrift industry. Freddie and
                         • In 1970, to deal with regulatory impedi-                Fannie engaged in “swap” transactions
                           ments in getting mortgage money to                      that allowed S&Ls to liquidate mort-
                           California, the Federal Home Loan                       gage portfolios without recognizing
                           Mortgage Corporation (ultimately nick-                  losses. In this way, they were able to
                           named Freddie Mac) was formed as a gov-                 expand their lending even as they were
                           ernment agency.                                         failing. With one hand—the GSEs—gov-
                         • Throughout the 1970s the role of the                    ernment was handing the S&Ls money
                           GSEs expanded. The savings and loan                     to gamble, while with the other hand—
                           industry, which at the time dominated                   the Resolution Trust Corporation—the
                           mortgage finance, was plagued by disin-                 government was absorbing the losses.
                           termediation. Regulation Q, which lim-                • In 1989, Freddie Mac was sold to private
                           ited the interest rate that thrifts could               shareholders, just as Fannie Mae had
                           pay to their depositors, was causing an                 been in 1968. Freddie Mac proceeded to
                           outflow of funds from the S&Ls. That                    grow dramatically, and the two GSEs
                           was another classic example of a govern-                held just over 50 percent of all mortgage
                           ment intervention without a viable exit                 debt outstanding in 2003.
                           strategy. Regulation Q was not sustain-               • In 1992 Congress created a single regula-
  Strong lobbying          able. However, lifting that regulation                  tor, called the Office of Federal Housing
   by Fannie Mae           would have raised the thrifts’ cost of                  Enterprise Oversight, to oversee Freddie
                           funds, making many of them insolvent.                   Mac and Fannie Mae.
 and Freddie Mac           Ultimately, the regulation was lifted, and
    was sufficient         many S&Ls went under, at a cost to tax-                Congress never explicitly said that it was
      to offset the        payers of more than $100 billion.                  designing a mortgage finance system based
                         • Regulation Q helped to cause the down-             on this duopoly. However, strong lobbying
      warnings of          fall of the S&L industry. However, the             by Fannie Mae and Freddie Mac was suffi-
      many public          large losses incurred by taxpayers were the        cient to offset the warnings of many public
                           result of flaws in the deposit insurance           officials that the dominance of the GSEs was
 officials that the        system. In response to the losses on the           unwise.
dominance of the           S&Ls, the government reformed the way                  Concerns about the GSEs spanned the polit-
GSEs was unwise.           that deposit insurance was implemented.            ical spectrum. Lawrence Summers, Treasury



                                                                          4
Secretary under President Bill Clinton, com-                Congress was reluctant to restrain the         The overall policy
plained in 1999 of the anomalous status of the              market. Instead, even though the GSEs          of promoting
GSEs. When the crisis broke this July, Summers              were not supposed to purchase high-risk
was understandably bitter. On a web site called             mortgages, under pressure from Congress        home ownership
Creative Capitalism, he wrote:                              they bought hundreds of billions of dol-       was carried to
                                                            lars of securities backed by subprime
   What went wrong? The illusion that the                   loans.
                                                                                                           excess.
   companies were doing virtuous work                    2. Even taking as given the goal of expand-
   made it impossible to build a political                  ing home ownership, the public policy
   case for serious regulation. When there                  case for subsidizing mortgage finance
   were social failures the companies                       was weak. Rather than constituting a
   always blamed their need to perform for                  “positive externality,” the heavy load of
   the shareholders. When there were busi-                  mortgage indebtedness posed a major
   ness failures it was always the result of                systemic risk.
   their social obligations. Government                  3. The case for using the GSEs as a vehicle
   budget discipline was not appropriate                    to subsidize mortgage finance was weak-
   because it was always emphasized that                    er still. As Summers and others have
   they were “private companies.” But mar-                  pointed out, the GSE structure serves to
   ket discipline was nearly nonexistent                    privatize profits and socialize losses.
   given the general perception—now vali-                4. Even if one thought that home owner-
   dated—that their debt was government                     ship was worth encouraging, mortgage
   backed. Little wonder with gains priva-                  debt was worth subsidizing, and the GSE
   tized and losses socialized that the                     structure was viable, allowing the GSEs
   enterprises have gambled their way into                  to assume a dominant role in mortgage
   financial catastrophe.2                                  finance was a mistake. The larger they
                                                            grew, the more precarious our financial
    However, Summers was far from a lonely                  markets became. It reached the point
critic of the GSEs. Lawrence J. White, who                  where the health of the entire financial
served on the board of the agency regulating                system appeared to depend on the
Freddie Mac from 1986 through 1989, wrote                   health of the GSEs.
a study for the Cato Institute in 2004 in
which he advocated full privatization of the
GSEs.3 He suggested having the government                  The Latest Legislation
disavow any guarantees to GSE investors.
    That same year, in Privatizing Fannie Mae,            In July 2008, Congress passed comprehen-
Freddie Mac, and the Federal Home Loan Banks:         sive legislation aimed at the housing market,
When and How, Peter J. Wallison, Bert Ely, and        including some provisions pertaining to the
Thomas J. Stanton proposed that steps be              GSEs. The legislation provides for a multi-year
taken to level the playing field so that banks        increase in the ceiling on loans eligible for pur-
could compete with GSEs, thereby reducing             chase by the GSEs, to $625,000. What is more
the dependency of the housing finance sys-            important, in order to restore investor confi-
tem on GSEs.                                          dence in GSE securities, the new law gives the
    In hindsight, knowing what we know                U.S. Treasury the authority to extend almost
today, we can say that:                               unlimited credit to the GSEs and even to pur-
                                                      chase equity in the companies. Lastly, the leg-
   1. The overall policy of promoting home            islation creates a new independent regulatory
      ownership was carried to excess. By 2006,       agency to oversee the GSEs.
      the demand for housing had boosted                  It appears that the intent of Congress is to
      prices to unsustainable levels. However,        keep the GSEs substantially as they are.



                                                  5
                       Freddie Mac and Fannie Mae are supposed to                existing personnel out of the Department of
                       continue to add to their portfolios. As long as           Housing and Urban Development. Its perma-
                       their financial condition does not deteriorate            nent director will be appointed by the next pres-
                       radically, the management and ownership                   ident, and the transition is not expected to be
                       structure of the GSEs will remain unchanged.              complete until at least July of 2009.
                          In short, the new legislation contemplates
                       business as usual. The GSEs will continue to
                       serve as the conduit for an indirect subsidy to                         Alternatives
                       home buyers, with GSE shareholders getting
                       much of the profits and taxpayers bearing                   The attempt to preserve the status quo is
                       the costs and, most importantly, the risks.               not necessarily the best approach. In a July 27,
                                                                                 2008, newspaper column, Lawrence Summers
                                                                                 compared the Bear Stearns merger with the
                                Unwise Approach                                  housing legislation:

                          Current policy treats the GSEs as essential               Consider how much more problematic
                       to U.S. housing finance. That is an unwise                   the Bear Stearns response would have
The risks involved     approach. It makes the housing market unnec-                 been had policymakers signalled their
       in mortgage     essarily fragile. It sets up a permanent conflict            commitment to back the company’s lia-
 lending would be      between shareholders and taxpayers, to be                    bilities without limit; left management
                       mediated by an untried regulatory agency.                    in place with no change in the business
      better spread       The U.S. mortgage market is the largest                   model; and allowed dividends to be paid
 among dozens of       financial market in the world. When two                      and shareholders to keep going with
                       firms together hold more than one-third of                   hope for a better tomorrow. Yet all of
       institutions,   the outstanding mortgage debt, the entire                    these elements are present in the cases
        rather than    financial system is fragile. The risks involved              of Fannie and Freddie.4
   concentrated in     in mortgage lending would be better spread
                       among dozens of institutions, rather than                     Summers compared the status quo with
     the two GSEs.     concentrated in the two GSEs. With dozens                 the GSEs to the S&L crisis of the early 1980s,
                       of mortgage lenders, the failure of any one               where the attempt by Congress and regulators
                       firm could be dealt with through a merger,                to keep the thrifts going ultimately added to
                       rather than forcing the taxpayers to bear the             the taxpayers’ losses. Summers recommends
                       full brunt of the risk.                                   operating the GSEs as government corpora-
                          With GSE debt guaranteed by the govern-                tions for several years. At that time, he would
                       ment, there is a conflict between shareholders            sell whatever components of the GSEs are
                       and taxpayers. For shareholders, the way to max-          profitable to fully private entities.
                       imize profits is to borrow at the nearly risk-free            I would recommend a strategy that aims
                       rate (courtesy of the government’s guarantee) in          at spreading the mortgage business across a
                       order to finance risky lending. The incentive is to       wider range of financial institutions. In par-
                       take on a large portfolio with minimal capital.           ticular, regulators should contemplate freez-
                       The goal of protecting taxpayers requires the             ing the mortgage purchase activities of the
                       opposite: stiff capital requirements, with limits         GSEs while at the same time loosening the
                       on portfolio size and risk-taking. Until recently,        capital requirements for banks to hold low-
                       the Office of Federal Housing Enterprise Over-            risk mortgages.
                       sight was charged with implementing capital                   A freeze would have two beneficial effects.
                       regulations. It remains to be seen whether under          First, in the event that Freddie or Fannie
                       a new regulator, called the Federal Housing               becomes insolvent, the failure will be easier to
                       Finance Agency, this function will be handled             manage if the firm is smaller, with less uncer-
                       any more effectively. The FHFA merely takes the           tainty about the outlook for its mortgage port-



                                                                             6
folio. Second, a freeze would lead to an expan-              It might be argued that even an increase of
sion of the role of banks and other financial            one-fourth of one percentage point in mort-
institutions in the mortgage market, ultimately          gage rates is something that public policy
resulting in a stronger mortgage finance system.         should seek to avoid. If so, public policy can
    As the GSEs continue to purchase new                 avoid that consequence through a number of
mortgages, their portfolios become more dif-             means. One approach to consider would be
ficult for other firms to assess or to absorb.           to modify the capital requirements of banks.
New mortgages are the most difficult to assess               Banks, like the GSEs, have liabilities that are
in terms of risk. Within a few years, any flaws          guaranteed by the U.S. government. Bank de-
in the borrower’s capacity to manage credit              posits are insured by the Federal Deposit In-
have been exposed, and the initial trend of              surance Corporation. Accordingly, banks have
home prices in the area has been observed.               no inherent cost disadvantage relative to the
Once mortgages have been seasoned for sever-             GSEs in making mortgage loans. However,
al years, the default rate is usually predictable.       banks do have a regulatory disadvantage, based
    Assuming that the GSEs’ capital is sufficient        on differences in capital requirements. Reducing
to absorb any losses, it would be possible for the       or eliminating those differences would allow
government, within 5 to 10 years, to credibly            banks to offer mortgage loans at rates that com-
eliminate its guarantee of GSE liabilities. Today,       pete with GSE rates.
government cannot limit its guarantee, because               The main reason that the GSEs grew to
too many security-holders would be adversely             dominate the market for loans that fit their eli-
affected. However, in several years, when the            gibility criteria is that their capital require-
financial condition of the firms will be much            ments were derived from the default risks of
clearer and the size of their obligations will be        the mortgage loans. In contrast, banks have to
much smaller, the blank-check guarantee should           hold an amount of capital against their mort-
no longer be needed. Once the guarantee is elim-         gage assets that is higher, particularly for those
inated, the GSEs can resume their purchases of           mortgage loans with the lowest default risk.
new mortgages. At that point, they would face                Bank regulators could, on either a tempo-
the discipline of the capital markets, which             rary or permanent basis, reduce the capital
would make it extremely unlikely that their mar-         requirements for low-risk mortgages held by
ket shares would reach dangerously high levels.          banks. Low-risk mortgages would be mort-
    What would a GSE freeze do to the mort-              gages where the borrower makes a down pay-
gage market? Other lenders, primarily banks,             ment of 20 percent, or 10 percent with mort-
would have to step in and bear the default risk          gage insurance. These are the loans that are
and investment risk of mortgages. They tend              “conforming loans,” meaning that they fall            One approach
to charge higher rates than the lenders who              within the GSEs’ charters. Reduced capital
sell their loans to the GSEs. This can be seen in        requirements would encourage banks to com-
                                                                                                               might be to
the market for so-called “jumbo” loans, which            pete more aggressively for those loans, thereby       reduce the capital
are mortgages that are larger than the GSEs’             mitigating some of the impact of a freeze on          requirements
purchase limits. Historically, jumbo loans               new purchases by the GSEs.
have cost about one-fourth of one percentage                 One approach might be to reduce the cap-          for low-risk
point more than GSE-eligible loans. That                 ital requirements for low-risk mortgages pur-         mortgages
would suggest only a modest impact of losing             chased over the next three years, so that the
the GSE presence in the mortgage market.                 housing market can start to recover from the
                                                                                                               purchased over
    More recently, however, as mortgage-backed           collapse of prices in the past year. After three      the next three
investments have acquired a stigma, the spread           years, the capital requirements for new mort-         years, so that the
between jumbo rates and GSE-eligible rates has           gage purchases could be brought back to cur-
widened to a full percentage point. This sug-            rent levels, perhaps under a gradual phase-in.        housing market
gests that the impact of losing the GSE pres-                With or without modifying bank capital            can start to
ence could be that large.                                requirements, freezing GSE purchases would            recover.

                                                     7
                                serve to restructure the mortgage finance sys-
                                tem. The result would almost surely be an                              Notes
                                industry that is much less concentrated than       1. Dawn Kopecki and Bryan Keogh, “Fannie Mae
                                the current duopoly. A housing finance sys-        Pays Record Spreads on Two-Year Note Sale (Up-
                                tem that does not rely so heavily on Freddie       date3),” Bloomberg.com, July 9, 2008, http://www.
                                Mac and Fannie Mae will be more robust.            bloomberg.com/apps/news?pid=newsarchive&sid=a
                                                                                   5DLtYxm1Y08
                                    There is no fool-proof system for handling
                                mortgage credit risk. We have to assume that       2. Lawrence Summers, “Our Creative Mortgage
                                sooner or later some of the institutions           Crisis?” Creative Capitalism: A Conversation, July
                                involved in mortgage finance will fail. The pol-   16, 2008, http://creativecapitalism.typepad.com/cre
                                                                                   ative_capitalism/2008/07/our-creative-mo.html.
                                icy should be to promote a housing finance
                                system where mortgage risk is spread among         3. Lawrence J. White, “Fannie Mae, Freddie Mac,
                                dozens of institutions. That way, the failure of   and Housing Finance: Why True Privatization Is
                                some firms can be resolved through mergers         Good Public Policy,” Cato Institute Policy Analysis
                                                                                   no. 528, October 7, 2004.
                                and orderly restructuring, without exposing
                                the financial system to the sort of catastroph-    4. Lawrence Summers, “The Way Forward for
                                ic risk that is represented by Fannie Mae and      Fannie and Freddie,” Financial Times, July 27, 2008,
                                Freddie Mac.                                       http://www.ft.com/cms/s/0/b150d388-5bf8-11dd-
                                                                                   9e99-000077b07658.html.


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