Housing Government-Sponsored Enterprises: A Single Regulator Will Better Ensure Safety and Soundness and Mission Achievement
Published: 2008-03-06T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The housing government-sponsored enterprises (GSEs)--Fannie Mae, Freddie Mac, and the Federal Home Loan Bank System (FHLBank System), play a critical role in the nation's housing finance system. However, concerns exist that the fragmented federal oversight structure for the GSEs is not well positioned to help ensure that they operate in a safe and sound manner and fulfill their housing missions. This testimony provides information on the GSEs' missions and risks, the current regulatory structure, and proposed regulatory reforms. To prepare this testimony, GAO relied on a substantial body of previous work and updated its analysis in light of recent events.
section_title: What GAO Found
paragraphs: While the GSEs provide certain public benefits, they also pose potential risks. Fannie Mae and Freddie Mac's primary activity involves purchasing mortgages from lenders and issuing mortgage-backed securities that are either sold to investors or held in the GSEs' retained portfolio. The 12 FHLBanks traditionally made loans to their members and more recently instituted programs to purchase mortgages from their members and hold such mortgages in their portfolios. While not obligated to do so, the federal government could provide financial assistance to the GSEs, if one or more experienced financial difficulties, that could result in significant costs to taxpayers. Due to the GSEs' large size, the potential also exists that financial problems at one or more of the GSEs could have destabilizing effects on financial markets. The current housing GSE regulatory structure is fragmented and not well equipped to oversee their financial soundness or housing mission achievement. The Office of Federal Housing Enterprise Oversight (OFHEO) is responsible for safety and soundness oversight of Fannie Mae and Freddie Mac while the Federal Housing Finance Board (FHFB) is responsible for safety and soundness and mission oversight of the FHLBank System. Both regulators lack key statutory authorities to fulfill their safety and soundness responsibilities as compared to the authorities available to federal bank regulators. For example, OFHEO and FHFB are not authorized to limit the asset growth of housing GSEs if capital falls below predetermined levels. Moreover, the Department of Housing and Urban Development (HUD), which has housing mission oversight responsibility for Fannie Mae and Freddie Mac, faces a number of challenges in carrying out its responsibilities. In particular, HUD may not have sufficient resources and technical expertise to review sophisticated financial products and issues. Creating a single housing GSE regulator could better ensure consistency of regulation among the GSEs. With safety and soundness and mission oversight combined, a single regulator would be better positioned to consider potential trade-offs between these sometimes competing objectives. To be effective, the single regulator must have all the regulatory oversight and enforcement powers necessary to address unsafe and unsound practices, respond to financial emergencies, assess the extent to which the GSEs' activities benefit home buyers and mortgage markets, and otherwise ensure that the GSEs comply with their public missions. To ensure the independence and prominence of the regulator and allow it to act independently of the influence of the housing GSEs, this new GSE regulator should be governed by a board or hybrid board structure.

section_title: Letter
paragraphs: I appreciate the opportunity to participate in today’s hearing to discuss  federal oversight of the housing government-sponsored enterprises  (GSEs), namely Fannie Mae, Freddie Mac, and the Federal Home Loan  Bank System (FHLBank System). The housing GSEs continue to play a  critical role in the nation’s housing finance system and this committee,  with input from a number of entities, is assessing the contributions the  GSEs may be able to make to address currently distressed housing market  conditions. However, as you know, the housing GSEs, which are large and  complex organizations with more than $6 trillion in outstanding  obligations, also pose potentially significant risks to taxpayers. When  Comptroller General Walker testified before this committee in April 2005,  he stated that the fragmented federal regulatory structure for the housing  GSEs was not well positioned to help ensure that they operate in a safe  and sound manner and thereby limit such risks. Further, he stated that the  fragmented regulatory structure did not provide adequate assurance to  Congress and the public that the GSEs were fulfilling their critical housing  missions. As the Comptroller General testified, and I plan to emphasize  today, the establishment of a single federal regulator with adequate  authorities to oversee all housing GSE activities is critical to helping  ensure that the housing GSEs’ financial soundness is secure while they  continue to provide opportunities to American homeowners.
To assist the committee in its oversight of the housing GSEs and their  regulation, my testimony today is divided into two sections. First, I will  provide an overview of the GSEs and their missions, identify the risks they  pose to taxpayers and the financial system, and describe the current  regulatory structure, which is divided among the Office of Federal Housing  Enterprise Oversight (OFHEO), the Department of Housing and Urban  Development (HUD), and the Federal Housing Finance Board (FHFB).  Second, I will identify deficiencies in the current regulatory structure and  discuss how a single regulator that is endowed with adequate legal  authorities and governed by a board or hybrid board structure is, in our  view, the best potential means to help ensure that the GSEs meet their  housing-related missions while doing so in a safe and sound manner.
To prepare for this testimony, we relied heavily on a substantial amount of  work that we have done on the housing GSEs and their regulatory  oversight in the past (see Related GAO Products), and we also reviewed  our historical positions in light of recent events. We conducted this work  in Washington, D.C. in accordance with generally accepted government  auditing standards. Those standards require that we plan and perform the  audit to obtain sufficient, appropriate evidence to provide a reasonable  basis for our findings and conclusions based on our audit objectives. We  believe that the evidence obtained provides a reasonable basis for our  findings and conclusions based on our audit objectives.
subsections: section_title: Overview of the Housing GSEs, Their Risks, and Regulatory Structure
paragraphs: I would like to begin my testimony by briefly describing the missions and  activities of each of the GSEs, and the risks they pose to taxpayers. Then I  will describe the current GSE regulatory structure.
subsections: section_title: The Housing GSEs Share Similar Missions
paragraphs: Fannie Mae and Freddie Mac’s mission is to enhance the availability of  mortgage credit across the nation during both good and bad economic  times by purchasing mortgages from lenders (banks, thrifts, and mortgage  lenders), which then use the proceeds to make additional mortgages  available to home buyers. Most mortgages purchased by Fannie Mae and  Freddie Mac are conventional mortgages, which have no federal insurance  or guarantee. The companies’ mortgage purchases are subject to a  conforming loan limit that currently stands at a maximum of $729,750.  Although Fannie Mae and Freddie Mac hold some mortgages in their  portfolios that they purchased, most mortgages are placed in mortgage  pools to support mortgage-backed securities (MBS). MBS issued by Fannie  Mae or Freddie Mac are either sold to investors (off-balance sheet  obligations) or held in their retained portfolios (on-balance sheet  obligations). Fannie Mae and Freddie Mac guarantee the timely payment  of principal and interest on MBS that they issue.
The 12 FHLBanks that constitute the FHLBank System traditionally made  loans—also known as advances—to their members (typically banks or  thrifts) to facilitate housing finance and community and economic  development. FHLBank members are required to collateralize advances  with high-quality assets such as single-family mortgages. More recently,  the FHLBanks initiated programs to purchase mortgages directly from  their members and hold them in their retained portfolios. This process is  similar to Fannie Mae and Freddie Mac’s traditional business activities,  although the FHLBanks do not have the authority to securitize mortgages.
The activities of the housing GSEs generally have been credited with  enhancing the development of the U.S. housing finance market. For  example, when Fannie Mae and the FHLBank System were created during  the 1930s, the housing finance market was fragmented and characterized  by regional shortages of mortgage credit. It is widely accepted that the  activities of the housing GSEs helped develop a unified and liquid  mortgage finance market in this country.
section_title: Housing GSE Activities Involve Significant Risks
paragraphs: While the housing GSEs have generated public benefits, their large size  and activities pose potentially significant risks to taxpayers. As a result of  their activities, the GSEs’ outstanding debt and off-balance sheet financial  obligations total more than $6 trillion. The GSEs face the risk of losses  primarily from credit risk, interest rate risk, and operational risks.  Although the federal government explicitly does not guarantee the  obligations of GSEs, it is generally assumed on Wall Street that assistance  would be provided in a financial emergency. In fact, during the 1980s, the  federal government provided financial assistance to both Fannie Mae and  the Farm Credit System (another GSE) when they experienced difficulties  due to sharply rising interest rates and declining agricultural land values,  respectively.
More recently, the housing GSEs have experienced a variety of operational  and financial challenges, some of which are described below:    Starting in 2003, first Freddie Mac and then Fannie Mae were found to  have engaged in misapplication of relevant accounting standards and  earnings manipulation. The GSEs also misstated their incomes by billions  of dollars. Consequently, OFHEO required Fannie Mae and Freddie Mac to  develop capital restoration plans and both GSEs are still operating under  regulatory agreements, which require improvements in their operations.
According to FHFB, some FHLBanks did not embrace and implement  corporate governance and risk management tools necessary for their  complex and evolving operations, which resulted in operational and  financial challenges. In 2004, FHFB entered into supervisory written  agreements with the FHLBanks in Chicago and Seattle, which required a  variety of operational improvements. FHFB terminated the written  agreement with the Seattle bank in January 2007. FHFB also entered into a  related agreement with the Chicago bank in October 2007.
Fannie Mae reported that rising mortgage defaults and falling home prices  contributed to a $3.6 billion loss for the company in the last quarter of  2007. The GSE predicted that housing prices will continue to fall and that  its financial performance will deteriorate further. Similarly, Freddie Mac  reported a loss of about $2.5 billion for the same period, of which  approximately $2.3 billion is attributed to losses on derivative trades.
The GSEs also pose potential risks to the stability of the U.S. financial  system. In particular, if Fannie Mae, Freddie Mac, or the FHLBank System  were unable to meet their financial obligations, other financial market  participants depending on payments from these GSEs in turn might  become unable to meet their financial obligations. To the extent that this  risk, called systemic risk, is associated with the housing GSEs, it is based  primarily on the sheer size of their financial obligations. For example, as  discussed in OFHEO’s 2003 report on systemic risk, if either Fannie Mae  or Freddie Mac were to become insolvent, financial institutions holding  the enterprise’s MBS could be put into a situation where they could no  longer rely on those securities as a ready source of liquidity. Depending  on the response of the federal government, the financial health of the  banking segment of the financial services industry could decline rapidly,  possibly leading to a decline in economic activity. As another example,  derivatives counterparties holding contracts with a financially troubled  GSE could realize large losses if the GSE were no longer able to meet its  obligations. If such an event were to occur, widespread defaults could  occur in derivatives markets.
section_title: Housing GSE Regulatory Structure Is Divided among OFHEO, HUD, and FHFB
paragraphs: The current regulatory structure for the housing GSEs is divided among  OFHEO, HUD, and FHFB, as described below:    OFHEO is an independent office within HUD and is responsible for  regulating Fannie Mae and Freddie Mac’s safety and soundness. OFHEO  oversees the two GSEs through its authority to examine their operations,  determine capital adequacy, adopt rules, and take enforcement actions.  Although OFHEO’s financial plans and forecasts are included in the  President’s budget and are subject to the appropriations process, the  agency is not funded with tax dollars. Rather, Fannie Mae and Freddie  Mac pay annual assessments to cover OFHEO’s costs.
HUD is responsible for ensuring that Fannie Mae and Freddie Mac are  accomplishing their housing missions. HUD is to accomplish this  responsibility through its authority to set housing goals and review and  approve new programs, and through its general regulatory authority. HUD  is funded through appropriations.
FHFB is responsible for regulating the FHLBank System’s safety and  soundness as well as its mission activities. The agency has a five-member  board, with the President of the United States appointing four members— each of whom serves a 7-year term—subject to Senate approval. The fifth  member is the Secretary of HUD. The President also appoints FHFB’s  chair. Like OFHEO, FHFB carries out its oversight authorities through  examinations, establishing capital standards, rule making, and taking  enforcement actions. FHFB is funded through assessments of the 12  Federal Home Loan Banks and is not subject to the appropriations  process.
section_title: Housing GSE Regulatory Reform Is Necessary to Better Ensure Safety and Soundness and Mission Achievement
paragraphs: We continue to believe that the current fragmented regulatory structure  for the housing GSEs is inadequate to monitor these large and complex  financial institutions and their mission activities. Establishing a single  housing GSE regulator that is equipped with adequate authorities and  governed by a board would better ensure that the GSEs operate in a safe  and sound manner and fulfill their housing missions.
subsections: section_title: Current GSE Regulatory Structure Is Fragmented, OFHEO Lacks Key Authorities, and HUD’s Mission Oversight Capacity Is Questionable
paragraphs: The current fragmented structure of federal housing GSE regulation does  not provide for a comprehensive and effective approach to safety and  soundness regulation. Although the housing GSEs operate differently, they  share common characteristics as large and complex financial institutions.  For example, the GSEs rely on sophisticated strategies and activities, such  as the use of derivatives, to manage the interest rate and other risks that  are inherent in their operations. In recent years, the GSEs, as discussed  earlier, have not always demonstrated the capacity to effectively manage  the risks that they face.
Moreover, OFHEO, and FHFB to a lesser degree, lack key authorities to  fulfill their safety and soundness responsibilities, as described below:    Unlike bank regulators and FHFB, (1) OFHEO’s authority to issue cease  and desist orders does not specifically list an unsafe and unsound practice  as grounds for issuance and (2) OFHEO’s powers do not include the same  direct removal and prohibition authorities applicable to officers and  directors.
Bank regulators have prompt corrective action authorities that are  arguably more robust and proactive than those of OFHEO and FHFB.  These authorities require that bank regulators take specific supervisory  actions when bank capital levels fall to specific levels or provide the  regulators with the option of taking other actions when other specified  unsafe and unsound actions occur. Although OFHEO has statutory  authority to take certain actions when Fannie Mae or Freddie Mac capital  falls to predetermined levels, the authorities are not as proactive or broad  as those of the bank regulators. OFHEO also has established regulations  requiring specified supervisory actions when unsafe conditions are  identified that are not related to capital adequacy, but OFHEO’s statute  does not specifically mention these authorities. FHFB’s statute does not  establish a prompt corrective action scheme that requires specified  actions when unsafe conditions are identified. Although FHFB officials  believe they have all the authority necessary to carry out their safety and  soundness responsibilities, the agency has significant discretion in  resolving troubled FHLBanks. Consequently, there is limited assurance  that FHFB would act decisively to correct identified problems.
Unlike bank regulators—-which can place insolvent banks into  receivership—and FHFB, which can take actions to liquidate an FHLBank,  OFHEO is limited to placing Fannie Mae or Freddie Mac into a  conservatorship. Thus, it is not clear that OFHEO has sufficient authority  to fully resolve a situation in which Fannie Mae or Freddie Mac is unable  to meet its financial obligations.
In addition to concerns about OFHEO’s and FHFB’s authorities to fulfill  their safety and soundness responsibilities, the fragmentation of  authorities and responsibilities between OFHEO and HUD amplify our  significant concerns with HUD’s capacity as the mission regulator for  Fannie Mae and Freddie Mac. The ability for a regulator to assess tradeoffs  that may be present between mission achievement and financial  soundness, especially in the presence of the housing market turmoil we  are currently experiencing, is especially important. As stated in our  previous testimony, HUD officials we contacted said the department  lacked sufficient staff and resources necessary to carry out its GSE  mission oversight responsibilities. According to HUD’s Director of  Government-Sponsored Enterprise Oversight, HUD currently has a total of  about 17 full time positions that are dedicated to GSE mission oversight.  While HUD’s ability to ensure adequate resources for its GSE oversight  responsibilities is limited, its mission oversight responsibilities are  increasingly complex. For example, as we have noted in the past, it is not  clear that HUD has the expertise necessary to review sophisticated  financial products and issues, which may be associated with the  department’s program review and approval and general regulatory  authorities. In addition, without the authority to impose assessments on  Fannie Mae and Freddie Mac to cover the costs associated with their  mission oversight, it would appear that HUD will always be challenged to  fulfill its GSE mission oversight responsibilities.
section_title: A Single Housing GSE Regulator Equipped with Sufficient Authorities and Governed by a Board or Hybrid Board Structure Is Critical
paragraphs: To address the deficiencies in the current GSE regulatory structure that I  have just described, we have consistently supported and continue to  believe in the need for the creation of a single regulator to oversee both  safety and soundness and mission of the housing GSEs. A single regulator  could be more independent, objective, efficient, and effective than  separate regulatory bodies and could be more prominent than either one  alone. We believe that valuable synergies could be achieved and expertise  in evaluating GSE risk management could be shared more easily within  one agency. In addition, we believe that a single regulator would be better  positioned to oversee the GSEs’ compliance with mission activities, such  as special housing goals and any new programs or initiatives the GSEs  might undertake. This single regulator should be better able to assess the  competitive effects of these activities on all three housing GSEs and better  able to ensure consistency of regulation for GSEs that operate in similar  markets.
Further, a single regulator would be better positioned to consider potential  tradeoffs between mission requirements and safety and soundness  considerations, because such a regulator would develop a fuller  understanding of the operations of these large and complex financial  institutions. Some critics of combining safety and soundness and mission  have voiced concerns that doing so could create regulatory conflict for the  regulator. However, we believe that a healthy tension would be created  that could lead to improved oversight. The tradeoffs between safety and  soundness and compliance with mission requirements could be best  understood and accounted for by having a single regulator that has  complete knowledge of the financial conditions of GSEs, regulates the  mission goals Congress sets, and assesses efforts to fulfill them.
subsections: section_title: Adequate Regulatory Authorities Are Essential
paragraphs: It is essential that the new GSE regulator have adequate powers and  authorities to address unsafe and unsound practices, respond to financial  emergencies, and ensure that the GSEs comply with their public missions.  These authorities include (1) cease and desist authority related to unsound  practices, (2) removal and prohibition authority related to officers and  directors, (3) prompt corrective action authority for inadequate capital  levels as well as other unsafe and unsound conditions, and (4) authority to  resolve a critically undercapitalized GSE, which may include placing it into  receivership. Additionally, the new housing GSE regulator should have the  authority to adjust as necessary the housing enterprises’ minimum and  risk-based capital requirements to help ensure their continued safety and  soundness.
We also believe that the new GSE regulator should be tasked with the  responsibility of conducting research on the extent to which the housing  GSEs are fulfilling their housing and community development missions.  There are already questions about the extent to which the housing GSEs’  retained mortgage holdings benefit housing finance markets. Moreover,  studies by federal agencies, academics, and the GSEs have estimated the  extent to which Fannie Mae’s and Freddie Mac’s activities generate  savings to home buyers and have reached differing conclusions. Additional  studies may be needed to more precisely estimate the extent to which the  GSEs’ activities benefit home buyers. Further, there is limited empirical  information on the extent to which FHLBank advances lower mortgage  costs for home buyers or encourage lenders to expand their commitment  to housing finance. Without better information, Congress and the public  cannot judge the effectiveness of the GSEs in meeting their missions or  whether the benefits provided by the GSEs’ various activities are in the  public interest and outweigh their financial and systemic risks.
section_title: New GSE Regulator Should Have a Board or Hybrid Board/Director Governance Structure
paragraphs: In determining the appropriate structure for a new GSE regulator, I note  that Congress has authorized two different structures for governing  financial regulatory agencies: a single director and board. Among financial  regulators, single directors head the Office of the Comptroller of the  Currency, the Office of Thrift Supervision and OFHEO, while boards or  commissions run FHFB, the Securities and Exchange Commission, and the  Board of Governors of the Federal Reserve System, among others. The  single director model has advantages over a board or commission; for  example, the director can make decisions without the potential hindrance  of having to consult with or obtain the approval of other board members.
However, in our previous work, we have stated that a “stand-alone” agency  with a board of directors would better ensure the independence and  prominence of the regulator and allow it to act independently of the  influence of the housing GSEs, which are large and politically influential. A  governing board may offer the advantage of allowing different  perspectives, providing stability, and bringing prestige to the regulator.  Moreover, including the Secretaries of Treasury and HUD or their  designees on the board would help ensure that GSE safety and soundness  and housing mission compliance issues are both considered.
I would note that in other regulatory sectors—-besides financial  regulation—-Congress has established alternative board structures that  could be considered as potential models for the new GSE regulator. One  such alternative structure would be the hybrid board/director governance  model. Under such an approach, a Presidentially appointed and Senate- confirmed agency head could report to a board of directors consisting of  secretaries from key executive branch agencies, such as Treasury and  HUD. Having board members from the same political party could lessen  some of the tensions and conflicts observed at boards purposefully  structured to have a split in membership along party lines. However, a  board composed of members from the same political party may not benefit  from different perspectives to the same extent as a board with members  from different political parties. Therefore, an advisory committee to the  regulator could be formed to include representatives of financial markets,  housing, and the general public. This advisory committee could be  required to have some reasonable representation from different political  parties.
section_title: Regulatory Funding Structure
paragraphs: Finally, I would like to comment on issues surrounding the potential  funding arrangements for a new housing GSE regulator. Exempting the  new GSE regulator from the appropriations process would provide the  agency with the financial independence necessary to carry out its  responsibilities. More importantly, without the timing constraints of the  appropriations process, the regulator could more quickly respond to  budgetary needs created by any crisis at the GSEs. However, being outside  the appropriations process can create tradeoffs. First, while the regulator  will have more control over its own budget and funding level, it could lose  the checks and balances provided by the federal budget and  appropriations processes or the potential reliance on increased  appropriations during revenue shortfalls. As a result, the regulator may  need to establish a system of budgetary controls to ensure fiscal restraint.
Second, removing the regulator from the appropriations process could  diminish congressional oversight of the agency’s operations. This tradeoff  could be mitigated through increased oversight by the regulator’s  congressional authorizing committees, such as a process of regular  congressional hearings on the new GSE regulator’s operations and  activities.
Mr. Chairman, this completes my prepared statement. I would be happy to  respond to any questions that you or other Members of the Committee  may have.
section_title: GAO Contacts and Staff Acknowledgments
paragraphs: For further information regarding this testimony, please contact William B.  Shear, Director, at (202) 512-8678 or shearw@gao.gov. Individuals making  contributions to this testimony include Marianne E. Anderson, Wesley M.  Phillips, and Karen C. Tremba.
section_title: Related GAO Products
paragraphs: Federal Home Loan Banks: Too Soon to Tell the Potential Impact of  Excess Stock Rule on the Affordable Housing Program. GAO-07-878R.  Washington, D.C.: June 22, 2007.
Housing Government-Sponsored Enterprises: A New Oversight Structure  Is Needed. GAO-05-576T. Washington, D.C.: April 21, 2005.
Federal Home Loan Bank System: An Overview of Changes and Current  Issues Affecting the System. GAO-05-489T. Washington, D.C.: April 13,  2005.
Government-Sponsored Enterprises: A Framework for Strengthening  GSE Governance and Oversight. GAO-04-269T. Washington, D.C.:  February 10, 2004.
Federal Home Loan Bank System: Key Loan Pricing Terms Can Differ  Significantly. GAO-03-973. Washington, D.C.: September 8, 2003.
Financial Regulation: Review of Selected Operations of the Federal  Housing Finance Board. GAO-03-364. Washington, D.C.: February 28,  2003.
OFHEO’s Risk Based Capital Stress Test: Incorporating New Business Is  Not Advisable. GAO-02-521. Washington, D.C.: June 28, 2002.
Federal Home Loan Bank System: Establishment of a New Capital  Structure. GAO-01-873. Washington, D.C.: July 20, 2001.
Comparison of Financial Institution Regulators’ Enforcement and  Prompt Corrective Action Authorities. GAO-01-322R. Washington, D.C.:  January 31, 2001.
Capital Structure of the Federal Home Loan Bank System. GAO/GGD-99- 177R. Washington, D.C.: August 31, 1999.
Federal Housing Finance Board: Actions Needed to Improve Regulatory  Oversight. GAO/GGD-98-203. Washington, D.C.: September 18, 1998.
Federal Housing Enterprises: HUD’s Mission Oversight Needs to Be  Strengthened. GAO/GGD-98-173. Washington, D.C.: July 28, 1998.
Risk-Based Capital: Regulatory and Industry Approaches to Capital and  Risk. GAO/GGD-98-153. Washington, D.C.: July 20, 1998.
Government-Sponsored Enterprises: Federal Oversight Needed for  Nonmortgage Investments. GAO/GGD-98-48. Washington, D.C.: March 11,  1998.
Federal Housing Enterprises: OFHEO Faces Challenges in Implementing  a Comprehensive Oversight Program. GAO/GGD-98-6. Washington, D.C.:  October 22, 1997.
Government-Sponsored Enterprises: Advantages and Disadvantages of  Creating a Single Housing GSE Regulator. GAO/GGD-97-139.  Washington, D.C.: July 9, 1997.
Housing Enterprises: Investment, Authority, Policies, and Practices.  GAO/GGD-91-137R. Washington, D.C.: June 27, 1997.
Comments on “The Enterprise Resource Bank Act of 1996.” GAO/GGD- 96-140R. Washington, D.C.: June 27, 1996.
Housing Enterprises: Potential Impacts of Severing Government  Sponsorship. GAO/GGD-96-120. Washington, D.C.: May 13, 1996.
Letter from James L. Bothwell, Director, Financial Institutions and  Markets Issues, GAO, to the Honorable James A. Leach, Chairman,  Committee on Banking and Financial Services, U.S. House of  Representatives, Re: GAO’s views on the “Federal Home Loan Bank  System Modernization Act of 1995.” B-260498. Washington, D.C.: October  11, 1995.
FHLBank System: Reforms Needed to Promote Its Safety, Soundness,  and Effectiveness. GAO/T-GGD-95-244. Washington, D.C.: September 27,  1995.
Housing Finance: Improving the Federal Home Loan Bank System’s  Affordable Housing Program. GAO/RCED-95-82. Washington, D.C.: June 9,  1995.
Government-Sponsored Enterprises: Development of the Federal Housing  Enterprise Financial Regulator. GAO/GGD-95-123. Washington, D.C.: May  30, 1995.
Federal Home Loan Bank System: Reforms Needed to Promote Its Safety,  Soundness, and Effectiveness. GAO/GGD-94-38. Washington, D.C.:  December 8, 1993.
Improved Regulatory Structure and Minimum Capital Standards Are  Needed for Government-Sponsored Enterprises. GAO/T-GGD-91-41.  Washington, D.C.: June 11, 1991.
Government-Sponsored Enterprises: A Framework for Limiting the  Government’s Exposure to Risks. GAO/GGD-91-90. Washington, D.C.: May  22, 1991.
Government-Sponsored Enterprises: The Government’s Exposure to  Risks. GAO/GGD-90-97. Washington, D.C.: August 15, 1990.
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