United States General Accounting Office

GAO Report to Congressional Committees

December 1995 RESOLUTION TRUST

CORPORATION

Performing Assets Sold

to Acquirers of

Minority Thrifts

GAO/GGD-96-44

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-260116 

December 22, 1995

The Honorable Alfonse M. D’Amato

Chairman

The Honorable Paul S. Sarbanes

Ranking Minority Member

Committee on Banking, Housing, and

 Urban Affairs

United States Senate

The Honorable James A. Leach

Chairman

The Honorable Henry B. Gonzalez

Ranking Minority Member

Committee on Banking and

 Financial Services

House of Representatives

As required by the Resolution Trust Corporation (RTC) Completion Act,1

we have reviewed RTC’s efforts to sell performing assets to acquirers of

failed thrifts under the minority preference resolutions program. The act

required us to annually assess RTC’s determination of fair market value of

performing assets and determine the number and type of assets sold under

the program.

During fiscal year 1994, there were no transfers of assets under the

minority preference resolutions program. This report covers asset

transfers occurring in fiscal year 1995. This will be our only report on this

subject since RTC has resolved all of the failed thrifts it received and all

thrifts taken over in the future will be resolved by the Federal Deposit

Insurance Corporation (FDIC). FDIC is not required by law to establish a

similar asset transfer program.

Results in Brief On the basis of our discussions with firms experienced in pricing large

volumes of mortgage loans and our review of mortgage loan valuation

literature, we found that RTC had established a reasonable process

anchored to agency2

 and mortgage securities markets standards. This

process allowed for the independent valuation of 1- to 4-family residential

mortgage loans that were offered for sale to minority acquirers. RTC

1

The Resolution Trust Corporation Completion Act, P. L. 103-204, 107 Stat. 2369, 2378 (1993).

2

Agency refers to the Federal National Mortgage Association (Fannie Mae), Federal Home Loan

Mortgage Corporation (Freddie Mac), and Government National Mortgage Association (Ginnie Mae).

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contracted with two independent valuation contractors, experienced in

mortgage securities markets, to provide separate prices for each loan,

which RTC then averaged and offered to the minority acquirer as the final

price. By removing itself from the initial phase of the loan pricing process,

RTC demonstrated that it was committed to establishing a process that was

equitable and fair to minority acquirers but that, at the same time,

attempted to maximize total return on the disposition of assets as required

by law. Under this program, 11 of the 14 minorities who bought thrifts

from RTC purchased 4,063 1- to 4-family residential mortgage loans.

Moreover, to price the loans, the two valuation contractors appeared to

have established a reasonable methodology that considered and adjusted

for movements in interest rates, credit risk sensitivity, and the fact that

these were RTC loans. Further, officials at Fannie Mae and Freddie Mac

found the pricing methodology used by the valuation contractors to be

generally consistent with their approaches.

In commenting on a draft of this report, RTC’s Vice President for Asset

Management and Sales stated that RTC agreed with our findings, as well as

with our description of its program to sell performing assets to acquirers

of minority thrifts.

Background RTC was required by law to assist minorities to acquire failed thrifts.

Specifically, the RTC Completion Act required RTC to give preference to any

offer from minority bidders for acquiring failed thrifts located in

predominantly minority neighborhoods (PMN) that would result in the

same cost to RTC as determined under section 13(c)(4) of the Federal

Deposit Insurance Act, as amended by the Federal Deposit Insurance

Corporation Improvement Act of 1991. This section of the act requires RTC

to choose the alternative for resolving a failed thrift that results in the least

cost to RTC. Additionally, a minority acquirer of a thrift in a PMN was to

have first priority in the deposition of performing assets of failed thrifts.

To satisfy these requirements, RTC established its minority preference

resolutions program in February 1994. Under this multifaceted program,

RTC was to offer a failed minority-owned thrift to investors of the same

minority group before offering it to others. Additionally, bidding

preferences were to be given to offers from minority-owned financial

institutions to acquire any failed thrift whose home office was located in a

PMN or that had 50 percent or more of its offices in PMNs, provided that this

preference would not increase the cost to RTC. Specifically, under the

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preference, if a minority bidder was within 10 percent of the highest bid

made by a nonminority bidder, then a “best and final” round of bidding

was to take place between them.

As part of this program, RTC was also to provide a winning minority bidder

with (1) interim capital assistance of up to two-thirds of the required

regulatory capital and (2) branch facilities, located in a PMN and owned by

RTC, on a rent-free basis for 5 years. In July 1994, RTC issued procedures for

selling 1- to 4-family residential mortgage loans to acquirers of whole

thrifts or branches under this program. In essence, after the sale of a thrift,

RTC was to have 45 days to develop the preliminary pricing of the loans to

be sold, and the minority acquirer was to have up to 90 days to review the

loans. When this review was completed, RTC was to give the acquirer the

final sales prices for the loans. The acquirer was then to have 3 days to

decide which loans to purchase and a fourth day to notify RTC of its choice.

Minority acquirers could purchase loans of up to 100 percent of the net

deposits assumed from RTC in the acquisition of the failed thrift.

The process RTC established to sell performing 1- to 4-family residential

mortgage loans to minority acquirers has undergone several changes, in

part because of concerns raised by a group of seven minority acquirers.

This group believed (1) that RTC should not be responsible for pricing the

loans, (2) that RTC’s current methodology resulted in the loans being

overpriced, and (3) that the resale provision was unfair. In March 1994, RTC

stated that it would have its own staff price the loans. However, to ensure

that the pricing was done in an equitable manner, in June 1994 RTC hired

two asset valuation contractors to independently price the mortgage loans,

thus removing itself from the pricing process. To ensure objectivity, RTC

awarded fixed-fee contracts whereby neither the sales price established

for the loans nor the price paid by the purchaser was a factor in

determining the fee paid to the asset valuation contractors.

Additionally, RTC’s March 1994 pricing procedures and mortgage loan sales

agreement stated that RTC would be entitled to receive 50 percent of the

acquirer’s profit if the acquirer sold any of the mortgage loans prior to 181

days after the closing of the sales agreement. However, by June 1994, RTC

had decided to eliminate this resale provision based on concerns raised by

the minority group.

Finally, under the provisions of the mortgage loan sale agreement, RTC was

expected to credit, to the minority acquirers who exercised their option to

purchase the mortgage loans, the interest accrued on the loans selected.

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The period of accrual was to begin 45 days after the signing of the

agreement and end on the day preceding the closing date of the

transaction. The accrued interest is defined in RTC’s minority loan pricing

procedures as the coupon interest rate on the loans less the average

federal funds’ rate during the accrual period.3

 However, to resolve a

contract dispute regarding the final pricing of the mortgage loans, RTC

provided the minority acquirers who decided not to purchase the

mortgage loans with the following option—the acquirer could choose not

to exercise the agreement on the loan portfolio, but rather receive the

interest accrued on the respective portfolio. Under this option, the

acquirer waived the right to purchase any 1- to 4-family residential

mortgage loans through the minority resolutions preference program.

Objectives, Scope,

and Methodology

The RTC Completion Act required that we submit an annual report to

Congress on transfers of performing assets by RTC to any acquirer. In

discussions with the oversight committees, it was agreed that our report

would focus on assets sold to minority acquirers. Specifically, the

objectives of our review were to (1) assess how RTC determined the fair

market value for the loans transferred and (2) ascertain the number and

description of performing loans transferred to minority thrifts.

Although the act required us to assess RTC’s determination of fair market

value for the loans transferred, we were unable to evaluate RTC’s

determination for the following reasons. First, fair market value is

commonly measured through competitive sales. Second, loans not

purchased by minority acquirers were sold in bulk, and sales prices were

not assigned to individual loans. Third, there were no data available to

compare the prices of the mortgage loans sold to minority acquirers with

the prices of other loans sold by RTC, because fewer whole loans were

available for sale once RTC’s securitization program started showing results

around June 1991.4

 Therefore, we focused on assessing the reasonableness

of the process RTC established to price the mortgage loans, including the

methodology used by RTC’s valuation contractors. To assess

reasonableness, we discussed the methodology and models used to price

the 1- to 4-family residential mortgage loans with RTC officials and the two

valuation contractors. While both valuation contractors were cooperative

in discussing the methodology in general, they were reluctant to discuss

their pricing models in detail. The valuation contractors considered the

3

The federal funds’ rate is the interest rate charged by banks to other banks in need of overnight loans.

4

Securitization is the process of assembling similar assets into pools that are used to collateralize

newly-issued securities, which are referred to as mortgage-backed securities.

Page 4 GAO/GGD-96-44 Resolution Trust Corporation
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specifics of these models to be proprietary because each firm has

individually and confidentially developed its own model. This did not

affect our determination of the reasonableness of the these models

because we were able to determine what factors were considered in the

models.

We also interviewed two of RTC’s three due diligence contractors to

understand their role and responsibilities.5

 Further, we reviewed RTC’s

policies and procedures and the valuation contractors’ operating

guidelines. To obtain additional perspectives on RTC’s process, we

interviewed officials of Freddie Mac and Fannie Mae who were involved in

valuing asset portfolios similar in type to RTC’s assets. To better

understand how mortgage loans are valued, we also reviewed academic

literature on mortgage loan valuation.

Finally, we were contacted by seven minority acquirers and their advisers

after they met with RTC and learned of our review. We subsequently met

with them to understand their experiences in purchasing loans from RTC

under the minority preference resolutions program. As a follow-up to that

meeting, we also interviewed their valuation contractor to obtain

information on the methodology used to assess the price of the loans.

To accomplish our second objective, which was to determine the number

and type of loans sold to minority acquirers, we obtained and analyzed,

but did not independently verify, RTC transaction reports showing asset

sales through the minority preference resolutions program. These reports

identify the type and number of loans sold, as well as their quality, price,

and purchaser. In addition, we also interviewed RTC officials regarding the

reliability of the reports.

We requested comments on a draft of this report from the Deputy and

Acting Chief Executive Officer of RTC or his designee. On November 28,

1995, RTC’s Vice President for Asset Management and Sales provided a

written response in which he concurred with our findings. These

comments are reprinted in appendix I.

We did our work between August 1994 and October 1995 in accordance

with generally accepted government auditing standards.

5

Due diligence is the process of evaluating information on the assets to fully assess their value.

Page 5 GAO/GGD-96-44 Resolution Trust Corporation
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RTC Established a

Reasonable Process

for Pricing Mortgage

Loans

The pricing of mortgage loans is a difficult and complex process requiring

the use of a sophisticated and technical methodology. RTC established a

reasonable process to price mortgage loans that was anchored to agency

and mortgage securities markets standards. This process provided for an

independent valuation of 1- to 4-family residential mortgage loans that

were offered for sale to minority acquirers of failed thrifts located in PMNs.

It is first important to note that RTC did not price the loans itself; instead, in

June 1994 it hired two independent valuation contractors experienced in

mortgage securities markets to determine the price of each mortgage loan.

Each valuation contractor was required to price the mortgage loans on an

individual basis, rather than at a portfolio level, because the acquirers

were allowed to purchase some, all, or none of the loans under the

minority preference resolutions program.

RTC also hired three due diligence contractors to preliminarily review each

loan to determine whether it was eligible for sale under the minority

preference resolutions program. To be eligible for sale under the program,

the loan had to be a performing 1- to 4-family residential mortgage type.

The purpose of RTC’s due diligence loan file review was to secure essential

information that could be used to evaluate the loans for sale. Some of the

essential documents included the loan note, mortgage insurance

certificate, title, appraisal, and credit and verification forms. The due

diligence contractors were not required to make judgments about credit

decisions or the loan’s salability. According to RTC’s valuation contractors,

the pricing of the mortgage loans began upon receipt of the loan data files

from RTC’s due diligence contractors. The valuation contractors were to

review these data files for completeness and accuracy and to notify RTC of

any errors or missing documents in the loan file.

RTC told us that it generally resolved these deficiencies by requiring the

due diligence contractors to update the loan file. The valuation contractors

said that the loans were then stratified to determine whether individual

loans conformed to secondary market standards.6

 Using RTC’s stratification

criteria, the two valuation contractors were to group the loans into three

levels, referred to as “strats.” According to RTC, its stratification criteria

were based on agency and secondary market standards and reflected the

minority preference resolutions program guidelines. See table 1 for RTC’s

criteria for the strat categories.

6

The secondary mortgage market standards as recognized by Fannie Mae, Freddie Mac, and other

investment firms include the rules for buying and selling mortgages that have already been originated

or issued.

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Table 1: RTC’s Strat Criteria

Strat category Criteria

Strat one Currently performing with no more than one 30-day

delinquency in the last 12 months

Immaterial document deficiency

Strat two Currently may be 30-days delinquent or may have two

30-day late payments in the last 12 months

Immaterial document deficiency

Strat three Currently may have one 60-day or three 30-day late

payments in the last 12 months

Significant document deficiency

Note: Strat four loans are more than 60 days past due and are generally not offered under the

program.

Source: RTC Division of Asset Management and Sales.

Under stratification, the two valuation contractors assigned strat codes

based on the loan data provided by the due diligence contractors. The

valuation contractors’ pricing reports showed that they assigned the same

strat for the majority of the loans. The two valuation contractors said that,

in cases where there were missing loan data, the loans were considered to

be of lower quality and were therefore assigned to a higher strat category.

After loan stratification, both valuation contractors used standard

mortgage-backed security methodologies to price each RTC mortgage loan.

This was done to determine the mortgage loan’s market value as

objectively as possible. The initial step under this approach was to assign

each loan a benchmark price, which approximated the market value of a

mortgage loan at a given point in time. For example, Freddie Mac’s 1-year

adjustable rate mortgage price was generally used as the benchmark for

adjustable rate mortgages. According to one valuation contractor,

selecting an appropriate benchmark price is a critical step in this

methodology.

According to the valuation contractors, the agency benchmark price

assigned to each mortgage loan was first determined by matching a loan’s

characteristics to the most closely similar agency mortgage-backed

security.7

 Second, after the loan servicing fee was subtracted from the

7

Loan characteristics include such factors as collateral type, geographic location, and interest rate.

Page 7 GAO/GGD-96-44 Resolution Trust Corporation
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current rate on RTC’s mortgage loan,8 the loan’s interest rate and the

agency’s interest rate were matched. For example, a RTC fixed rate

mortgage loan with an 8-percent interest rate net of loan servicing would

be matched with an agency mortgage-backed security with an 8-percent

fixed rate. Next, an equivalent benchmark price from the mortgage-backed

security price database was selected. The two valuation contractors stated

that, when determining the preliminary and final prices, they were

required by RTC to use secondary market data from the close of business of

the Wednesday prior to their receiving the loan data files. This pricing

data, obtained from Knight-Ridder, was a composite of prices from seven

different sources,9

 updated daily. Thus, the pricing reflected the actual

market value of the mortgage loans purchased at that time. According to

one valuation contractor, consistently using one date in time minimized

subjectivity.

Once the agency benchmark price was determined, adjustments for

movement in interest rates and credit risk sensitivity were made. To

determine the adjustments for interest rate risk, both valuation

contractors said they used an analytical technique known as

option-adjusted spread model. This model priced a mortgage loan or

mortgage-backed security by simulating many different future patterns of

interest rates. The model then used these simulations and the specific

characteristics of the mortgage loan to predict prepayments, which

determined the cash flow of the mortgage. Finally, the model matched the

predicted cash flow to the current mortgage prices, to determine the price

for the mortgage in question.

In addition to the adjustments made for interest rate risks, assessments for

credit risk were done to estimate the probability of default. To determine

the discounts for credit risk, both contractors analyzed each loan and

assigned it a risk weight based on characteristics that affect risk. These

risk characteristics include loan-to-value (LTV) ratio, geographic location,

mortgage insurance, and delinquency status.10 Both valuation contractors

agreed that an important variable in determining the severity of risk was

the current LTV ratio, because it provided a reliable valuation of the

collateral. In general, the higher the LTV the greater the risk. After the risk

weights were assigned, they were multiplied together to obtain the total

8

Loan servicing was initially removed so that the model would be on a par with the agency benchmark,

since Fannie Mae and Freddie Mac were not involved in loan servicing. However, after the benchmark

was determined, loan servicing was added back to RTC’s mortgage loan benchmark.

9

These seven sources included Fannie Mae, Freddie Mac, and Ginnie Mae mortgage securities.

10Loan-to-value ratio refers to the amount borrowed compared to the cost or value of the property

purchased.

Page 8 GAO/GGD-96-44 Resolution Trust Corporation
B-260116 

credit risk. The contractors acknowledged that this part of the process

was slightly subjective, but they agreed that this was an accepted

technique in the secondary market.

The final adjustments were for the strat category, unusual loan types (such

as balloon mortgages where the balance of the loan was due in one lump

sum on a specified date), and the fact that these were RTC loans from a

failed thrift. The two valuation contractors also said that determining

these adjustments was a subjective matter, but both believed that correct

assessments of these discounts depended heavily on previous experience

in valuing and marketing RTC assets—experience which both contractors

possessed.

Each valuation contractor provided RTC with each loan’s final price and

strat category. After receiving the two reports, RTC averaged the two loan

prices. The averaged price was offered to the minority acquirers as the

final price. RTC’s data showed that, although the two contractors worked

independently to price the 4,063 mortgage loans, there were fewer than

100 cases in which they differed on the final price of the mortgage loan.

The difference in price was usually less than half a percent. However, in

cases where they differed significantly, RTC required both valuation

contractors to reprice the loans.

We discussed the mortgage-backed securities approach used by RTC’s

contractors with officials from Fannie Mae and Freddie Mac, who said that

the methodology appeared to be reasonable. Specifically, the officials said

that the methodology was similar to the approach they used to value

mortgage loans and contained the elements necessary to value mortgage

loans. For example, although officials at Fannie Mae and Freddie Mac

would not discuss the specifics of their models because they are

considered proprietary, they explained that measuring interest rate

movement and credit risk sensitivity are very important steps in valuing

mortgage loans.

Alternative Pricing

Methodology

Proposed by Some

Minority Acquirers

Seven minority acquirers and RTC were unable to agree on the mortgage

loan prices. These acquirers believed that the mortgage loans were

overpriced. They also believed that RTC’s pricing methodology did not

establish the fair market value of the mortgage loans. They therefore

discussed with RTC the possibility of using an alternative methodology to

price the loans. RTC decided not to use the alternative methodology

proposed by the minority acquirers because it believed that the

Page 9 GAO/GGD-96-44 Resolution Trust Corporation
B-260116 

methodology being used established a fair market value for the loans and

that none of the mortgage loans were overpriced.

The alternative methodology proposed by the minority acquirers was

similar to the asset valuation reviews (AVR) used by RTC in 1992. Under the

AVR process, RTC hired independent contractors to review samples of

assets to estimate the potential loss for each asset category held by failed

thrifts. AVR computes the present value of such assets using a discount rate

based on secondary markets and adjusted for risk-related factors such as

loan documentation. The estimated recovery values were not determined

for individual loans in a portfolio, but rather for the category as a whole.

In their efforts to demonstrate that the mortgage loans were overpriced,

the seven minority acquirers contracted with a firm to complete an

analysis of the mortgage loans RTC made available for sale under the

minority preference resolutions program. While the approach of the

minority acquirers’ contractor was somewhat similar to that used by RTC’s

contractors, there were also fundamental differences. For example, RTC’s

contractors stratified and assigned benchmarks to each loan, while the

minority acquirers’ contractor stated that benchmarks were not

determined for individual loans, but rather for the portfolio as a whole.

Additionally, RTC’s contractors and the minority acquirers’ contractor also

differed on the coefficients, which are risk weight factors used in

calculating the loan price.

As previously stated, the approach of the minority acquirers’ contractor

was similar to RTC’s AVR process. In summary, to determine the mortgage

loan price, the minority acquirers’ contractor said it used a discounted

cash flow methodology based on the assets’ expected income and yields

on mortgage trading in the secondary market. The price was then adjusted

for risk-related factors, such as the probability of default, loan quality, and

document deficiencies. To determine the adjustments for movement in

interest rates, prepayment speeds were estimated using the Wall Street

consensus speeds for like mortgage loan rates. Cash flows for each loan

type were calculated using loan characteristics and prepayment speeds.

These cash flows were discounted to determine the market value of the

loans. Finally, the minority acquirers’ contractor believed that a yield

premium, to account for the fact that the loans were being provided in

conjunction with an acquisition of marginal quality deposit liabilities, was

also appropriate.

Page 10 GAO/GGD-96-44 Resolution Trust Corporation
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The seven minority acquirers and their contractor contended that the AVR

approach was an acceptable methodology to price the assets because RTC

had used it in the past. However, an RTC official stated that their process

for pricing mortgage loans had evolved over the years and that they no

longer used the AVR approach. RTC believed that the current

mortgage-backed security approach resulted in a better determination of

fair market value and attempted to maximize total return on the

disposition of a failed thrift’s assets, as required by law.

Loans Sold to

Minority Acquirers

RTC set aside about $3 billion in residential mortgage loans for possible

sale to minority acquirers through its minority preference resolutions

program. Between January 1994 and September 1995, RTC offered 16 pools

of performing 1- to 4-family residential mortgage loans to the 14 minority

acquirers who purchased failed thrifts located in PMNs. As of October 11,

1995, 11 minority acquirers had purchased 4,063 mortgage loans for

$289.6 million. Table 2 provides detailed information on their 13

transactions.

Table 2: RTC Mortgage Loan Sales to

Minority Acquirers

Transaction Date of sale

Number of

loans

Purchase

price

(percent)

Purchase

price

(millions)

One 10-31-94 446 94.61% $30.6

Two 10-31-94 475 94.52 34.6

Three 11-08-94 161 95.83 11.0

Four 12-07-94 9 98.97 0.9

Five 12-20-94 1,132 82.68 45.1

Six 01-18-95 126 96.82 11.1

Seven 01-31-95 140 96.49 21.5

Eight 02-17-95 237 96.99 17.3

Nine 02-21-95 726 94.12 45.4

Ten 02-28-95 197 95.13 30.2

Eleven 05-31-95 354 96.87 32.3

Twelve 08-30-95 33 96.74 5.6

Thirteen 09-28-95 27 97.44 4.0

Total 4,063 $289.6

Note: Two minority acquirers exercised two loan sales transactions each.

Source: RTC Division of Asset Management and Sales.

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Additionally, our analysis of the final loan prices showed that, of the 4,063

mortgage loans, 64 percent, or 2,606, were sold for between 91 and

100 percent of the book value, as shown in figure 1.

Figure 1: Final Mortgage Loan Pricing

Distribution

11% • Less than 80 cents on the dollar

20% • 80 to 90 cents on the dollar

64%•

91 to 100 cents on the dollar

•

5%

Greater than 100 cents on the

dollar

Note: The total number of loans sold was 4,063.

Source: RTC Division of Asset Management and Sales.

Finally, as of October 11, 1995, RTC had paid $4 million in accrued interest

to the 11 minority acquirers who purchased mortgage loans and

$1.4 million in accrued interest to 3 minority acquirers who decided not to

exercise their option to purchase mortgage loans. RTC officials believe that

paying the $1.4 million in accrued interest was the best alternative to

resolving a contract dispute with the minority acquirers over the final

pricing of the mortgage loans. We did not determine whether this practice

was the best alternative to resolving the contract dispute because it was

outside the scope of our assignment.

Page 12 GAO/GGD-96-44 Resolution Trust Corporation
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We are sending copies of this report to other interested congressional

committees and subcommittees, RTC’s Deputy and Acting Chief Executive

Officer, and the Chairman of the Thrift Depositor Protection Oversight

Board. Copies will be made available to others upon request.

This report was prepared under the direction of Ronald L. King, Assistant

Director, Government Business Operations Issues. Other major

contributors to this report are listed in appendix II. If you have any

questions, please contact me on (202) 736-0479.

Gaston L. Gianni, Jr.

Associate Director, Government

 Business Operations Issues

Page 13 GAO/GGD-96-44 Resolution Trust Corporation
Contents

Letter 1

Appendix I 

Comments From the

Resolution Trust

Corporation

16

Appendix II 

Major Contributors to

This Report

17

Tables Table 1: RTC’s Strat Criteria 7

Table 2: RTC Mortgage Loan Sales to Minority Acquirers 11

Figure Figure 1: Final Mortgage Loan Pricing Distribution 12

Abbreviations

AVR Asset Valuation Review

FDIC Federal Deposit Insurance Corporation

LTV loan-to-value

PMN predominantly minority neighborhood

RTC Resolution Trust Corporation

Page 14 GAO/GGD-96-44 Resolution Trust Corporation
Page 15 GAO/GGD-96-44 Resolution Trust Corporation
Appendix I 

Comments From the Resolution Trust

Corporation

Page 16 GAO/GGD-96-44 Resolution Trust Corporation
Appendix II 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

Tammy R. Conquest, Senior Evaluator, Government Business Operations

 Issues

Michael M. Yacura, Evaluator

Office of the Chief

Economist,

Washington, D.C.

William McNaught, Economist

(247123) Page 17 GAO/GGD-96-44 Resolution Trust Corporation
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