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                                                                    EXHIBIT 99.3

     Interest Rate Risk Management Policy

     To the extent consistent with its election to qualify as a REIT, the
Company will follow an interest rate risk management policy intended to mitigate
the negative effects of major interest rate changes. The Company intends to
mitigate its interest rate risk from borrowings by attempting to control the
mismatch of the duration of its debts to the duration on its Mortgage Assets
financed with borrowings. Under normal market conditions, the Company will
attempt to target the difference between the market weighted average duration on
its Mortgage Assets financed with borrowings to the market weighted average
duration of such borrowings to one year or less, taking into account all hedging
transactions. There can be no assurance that the Company will be able to limit
such duration differences and there may be periods of time when the duration
difference will be greater than one year. This policy will be reviewed by the
Company's Board of Directors if the Company incurs long-term non-callable
borrowings and as market conditions change. In addition, the Company also
intends to manage differences in interest rate indices between its Mortgage
Assets and borrowings where adjustable rate Mortgage Assets are involved.

     In addition to the foregoing duration guidelines, the Company intends to
mitigate lifetime cap risk associated with its adjustable-rate Mortgage Assets.
The policy will be to attempt to limit the effective interest rate on
substantially all of the Company's liabilities as a whole to a rate equal to the
weighted average lifetime cap of its adjustable-rate Mortgage Assets. Under
current market conditions, the Company does not intend to enter into
transactions to mitigate its periodic cap risk. The Company will manage this
risk through its leverage and asset/liability policies.

     The Company intends to purchase from time to time interest rate caps,
interest rate swaps and similar instruments to attempt to mitigate the risk of
the cost of its variable-rate liabilities increasing beyond the earnings on its
Mortgage Assets during a period of rising rates. In this way, the Company
intends generally to hedge as much of the interest rate risk as is in its best
interests, given the cost of such hedging transactions and the need to maintain
the Company's status as a REIT. This determination may result in the Company
bearing a level of interest rate risk that could otherwise be hedged when the
Company believes, based on all relevant facts, that bearing such risk is
advisable. The Company may also, to the extent consistent with its compliance
with the REIT Provisions of the Code and Maryland law, utilize financial futures
contracts, options and forward contracts as a hedge against future interest rate
changes. The Company will not invest in financial futures contracts or options
thereon that would cause the Manager or the Company to have to register under
the Commodities Exchange Act. The Company's hedging strategy may lower the
earnings and dividends of the Company in the short-term in order to further the
objective of maintaining competitive levels of earnings and dividends over the
long-term. The Company does not intend to hedge for speculative purposes.

     The Company may elect to conduct a portion of its hedging operations
through one or more subsidiary corporations that would not be a Qualified REIT
Subsidiary and would be subject to federal and state income taxes. In order to
comply with the nature of asset tests applicable to the Company as a REIT, the
value of the securities of any such subsidiary held by the Company must be
limited to less than 5% of the value of the Company's total Mortgage Assets as
of the end of each calendar quarter and no more than 10% of the voting
securities of any such subsidiary may be owned by the Company. A taxable
subsidiary would not elect REIT status and would distribute any net profit after
taxes to the Company and its other stockholders. Any dividend income received by
the Company from any such taxable subsidiary (combined with all other income
generated from the Company's Mortgage Assets, other than Qualified REIT Real
Estate Assets) must not exceed 25% of the gross income of the Company.