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Written in a neutral regulatory tone, the document largely validates these criticisms via facts and analysis, and then proposes extensive recommendations for change. Second, it’s unreasonable to assume the design could work effectively through many decades of often unpredictable changes in markets, legislation, and regulation.
One facet of the legislation stipulated that Michigan land banks must be created by intergovernmental collaboration between a county and the state land bank. In the 20 years since this legislation, Michigan has formed 48 county land banks, one city land bank (DLBA), and the state land bank, which serves the remaining 35 counties.
This nearly-50-page document concluded that nonbank mortgage servicers (NMSs) collectively are a potential threat to financial stability. A focus on MBS securitized through the smaller Ginnie Mae can follow later, as legislation would likely be required.) I find these recommendations lacking for four main reasons.
As documented in the Government Accountability Office (GAO) study referenced in Part 1, homebuyers will almost always defer to a third party involved in the purchase transaction to select a title insurer. The FHFA, from its founding in 2008 to 2021, was an independent regulator. See [link]. 10 See [link]. See [link]. See [link].
In the years immediately following conservatorship (which began in September 2008), the FHFA increasingly took over setting the average G-fee. Not surprisingly, the two companies highly prioritized protecting those subsidies, which meant maintaining political support in Congress to ensure no legislation was passed to take them away.
The changes then became the subject of hearings and legislation in the Republican-controlled House of Representatives to reverse the changes. The RFI document 20 itself has given the FHFA an opportunity to explain what it did and why and to educate the public on various aspects of the topic. This claim is simply untrue.
Introduction Freddie Mac and Fannie Mae (F&F), the two large government-sponsored enterprises (GSEs), were placed into conservatorship in September 2008 at the height of the Great Financial Crisis, when the markets lost confidence in them. For example, see the September 2008, “Statement by Secretary Henry M. Paulson, Jr.
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