Housing Government-Sponsored Enterprises: A New Oversight Structure Is Needed
Published: 2005-04-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Serious concerns exist regarding the risk management practices and the federal oversight of the housing government-sponsored enterprises (GSE)--Fannie Mae, Freddie Mac, and the Federal Home Loan Bank System (FHLBank System), which had combined obligations of $4.6 trillion as of year-end 2003. In 2003, Freddie Mac disclosed significant accounting irregularities. In 2004, the Office of Federal Housing Enterprise Oversight (OFHEO) cited Fannie Mae for accounting irregularities and earnings manipulation. Fannie Mae has to restate its financial statements for 2001-2004 and OFHEO has required the GSE to develop a capital restoration plan. Also in 2004, the FHLBanks of Chicago and Seattle entered into written agreements with their regulator, the Federal Housing Finance Board (FHFB), to implement changes to enhance their risk management. To assist Congress in its housing GSE oversight, this testimony provides information on GSEs' missions and risks, the current regulatory structure, and proposed regulatory reforms.
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 mission achievement. For example, although all the GSEs face increasingly similar risks (particularly potential losses in their mortgage portfolios resulting from fluctuations in interest rates), OFHEO is responsible for Fannie Mae and Freddie Mac's safety and soundness oversight while FHFB is responsible for the safety and soundness and mission oversight of the FHLBanks. OFHEO also lacks key regulatory authorities necessary to fulfill its oversight responsibilities. 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 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 have a structure that consists of a board or a hybrid board and director model. To be effective, the single regulator must also have all the regulatory oversight and enforcement powers necessary to address unsafe and unsound practices, respond to financial emergencies, monitor corporate governance and compensation practices, 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.

section_title: Letter
paragraphs: I appreciate the opportunity to participate in today’s hearing to discuss  federal oversight of the housing government-sponsored enterprises (GSE),  namely Fannie Mae, Freddie Mac, and the Federal Home Loan Bank  System (FHLBank System). When I testified before this committee in  February 2004 on this same topic, it was shortly after Freddie Mac had  disclosed significant financial problems associated with its accounting  practices. Freddie Mac’s regulator—the Office of Federal Housing  Enterprise Oversight (OFHEO)—did not detect the GSE’s accounting  irregularities at an early stage. At that hearing, I discussed the need for the  establishment of a capable, credible, strong, and independent regulatory  structure to help ensure that the housing GSEs operate safely and soundly.  To accomplish this goal, GAO—and others—-proposed that Congress  replace the current fragmented regulatory structure for housing GSE  oversight with a single regulator that would be responsible for safety and  soundness and mission activities. Subsequently, this committee took the  lead in approving a strong bill to create a single GSE regulator.
Over the past year, the need for fundamental regulatory reform of the  housing GSEs has become even more clear and compelling. As you well  know, Fannie Mae has been found to have engaged in the misapplication  of accounting standards and earnings manipulation, and company staff  even allegedly falsified signatures on documents. Fannie Mae will have to  restate its financial statements for the past several years and OFHEO has  required the GSE to develop a capital restoration plan. I am encouraged  that OFHEO identified these deficiencies at Fannie Mae and has moved  aggressively to correct them. I also note that the FHLBank System’s  regulator—the Federal Housing Finance Board (FHFB)—has identified  risk management deficiencies at the Chicago and Seattle FHLBanks and  entered into written agreements with these institutions to correct  identified deficiencies. Nevertheless, I believe the evidence clearly shows  that the current regulatory structure is not well-equipped to oversee the  operations and effectively monitor the risks of the large and complex  housing GSEs, which had combined financial obligations of about $4.6  trillion at year-end 2003.
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 OFHEO, the Department of  Housing and Urban Development (HUD), and FHFB. Second, I will identify  deficiencies in the current regulatory structure and discuss how a single  regulator that is governed by a board and endowed with adequate legal  authorities 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 had done on the housing GSEs and their regulatory oversight  in the past (see Related GAO Products), but we also reviewed our  historical positions in light of recent events. We conducted our work in  Washington, D.C., in April 2005 in accordance with generally accepted  government auditing standards.
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 $359,650 for a single-family  home in most states. 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 currently have the authority to securitize  mortgages.
The housing GSEs’ activities have generally 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 housing GSEs’  activities 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 were about $4.6 trillion as of year-end 2003. 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. The potential exists that Congress and the executive branch  would determine that such assistance was again necessary in the event  that one or more of the GSEs experienced severe financial difficulties.  Because the markets perceive that there is an implied federal guarantee on  the GSEs’ obligations, the GSEs are able to borrow at interest rates below  that of private corporations.
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 may in turn become  unable to meet their financial obligations. To the extent that this risk,  called systemic risk, is associated with the housing GSEs, it is primarily  based 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 to 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 subject to Senate approval. 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: As I stated previously, OFHEO has moved aggressively over the past year  to identify and address risk management and accounting deficiencies at  Fannie Mae and Freddie Mac, and FHFB has entered into written  agreements with two FHLBanks to correct interest rate risk management  deficiencies. Nevertheless, 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 with a board  structure and equipping the agency with adequate authorities 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,  their business activities and risks are becoming increasingly similar. As I  described previously, the FHLBank System has established mortgage  purchase programs over the past several years and FHLBank System  mortgage holdings were $113 billion at year-end 2003. While still small  compared with Fannie Mae and Freddie Mac’s combined retained  mortgage portfolios of $1.3 trillion for the same time period, the FHLBank  System now operates more like Fannie Mae and Freddie Mac and is  increasingly incurring interest rate risks. Management of interest rate risk  for mortgage holdings involves the application of sophisticated risk- management techniques, including the use of financial derivatives.  Although such strategies are appropriate for risk management, they  require specialized expertise, sophisticated information systems, and an  understanding and application of sometimes complex accounting rules. In  my view, it simply does not make sense for the federal government to  entrust regulation of large and complex GSEs that are incurring similar  risks to two different regulators, which have different approaches to  examinations and setting capital standards.
Moreover, OFHEO, and FHFB to a lesser degree, lack key authorities to  fulfill their safety and soundness responsibilities, as described below:    Unlike with 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 has also established regulations  requiring specified supervisory actions when unsafe conditions are  identified that do not include capital, 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.
Finally, we have significant concerns about HUD’s capacity as the mission  regulator for Fannie Mae and Freddie Mac. As I stated in my testimony last  year, HUD officials we contacted said the department lacked sufficient  staff and resources necessary to carry out its GSE mission oversight  responsibilities. HUD officials said that although the GSEs’ assets had  increased nearly sixfold since 1992, HUD’s staffing had declined by 4,200  positions and GSE oversight—which consisted of about 13 full-time  positions—must compete with other department priorities for the limited  resources available. 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 with a Board or Hybrid Board/Director Governance Model and Equipped with Sufficient Authorities 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 housing  GSE 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 any of the GSEs might undertake. This single  regulator should be better able to assess these activities’ competitive  effects 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  trade-offs 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 trade-offs 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 GSEs’ financial condition, regulates the  mission goals Congress sets, and assesses efforts to fulfill them.
subsections: 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, 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.
In our previous work, however, 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 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, there would be a presidentially appointed  and Senate-confirmed agency head who would report to a board of  directors composed 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. A  board composed of members from the same political party, however, 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: Adequate Regulatory Authorities Are Essential
paragraphs: It is also 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, 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.
I would also like to comment on an area of recent debate concerning  discussions of GSE regulatory reform, i.e., restrictions on Fannie Mae’s  and Freddie Mac’s retained mortgage portfolios, which were  approximately $1.3 trillion as of year-end 2003. In testimony before this  committee on April 6, 2005, Federal Reserve Chairman Greenspan stated  that the GSEs’ large retained mortgage portfolios do not necessarily  benefit housing finance, are primarily intended to increase the GSEs’  profitability, and increase the potential for systemic financial risks. To  address these concerns, Chairman Greenspan called for limits on the  GSEs’ mortgage portfolios to be phased in over time. Moreover, Treasury  Secretary Snow also expressed concern about the GSEs’ mortgage  portfolios and called for limits on their size. We also have commented that  the GSEs’ housing portfolios raise potential risks, and their benefits to  housing finance markets are not clear. In my view, providing the new  regulator with strong criteria to evaluate the costs and benefits of the  GSEs’ mortgage portfolios and the authority to limit them, if necessary, is  essential. The criteria could include the extent to which the mortgage  portfolios enhance the GSEs’ housing mission, increase financial risks, and  raise financial stability concerns.
Further, the new housing GSE regulatory agency should be provided with  explicit authority to oversee the GSEs’ corporate governance and  management compensation practices. As I stated in my previous  testimony, while the GSEs should have been leaders with respect to  corporate governance, in many respects they were not. For example,  unlike leading organizations, the chairman of Fannie Mae’s board also  served as the GSE’s chief executive officer (CEO). I note that both Fannie  Mae and Freddie Mac have formally agreed with OFHEO to separate the  positions of chairperson of the board and CEO, thereby helping to ensure  that the GSE boards independently establish company policies that their  CEOs are responsible for carrying out. OFHEO also found that Fannie  Mae’s compensation system provided managers with financial incentives  to take actions—such as accounting irregularities—that increased the  GSE’s reported short-term profitability. Without the authority to police  such practices, the new regulator would not be able to fully carry out its  oversight responsibilities.
I also believe that the new GSE regulator should be tasked with the  responsibility to conduct research on the extent to which the housing  GSEs are fulfilling their housing and community development missions. As  I described earlier, there are already questions about the extent to which  the housing GSEs’ mortgage holdings benefit housing finance markets.  Moreover, federal agencies, academics, and the GSEs have initiated  studies that have estimated the extent to which Fannie Mae’s and Freddie  Mac’s activities generate savings to home buyers, which 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 virtually no 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: Regulatory Funding Structure
paragraphs: Finally, I would now 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 trade-offs. First, while the regulator  will have more control over its own budget and funding level, it will 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 would  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 trade-off  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 Thomas J.  McCool, Managing Director, at (202) 512-8678 or mccoolt@gao.gov; or  William B. Shear, Director, at (202) 512-4325 or shearw@gao.gov.  Individuals making contributions to this testimony include Allison M.  Abrams, Marianne E. Anderson, Wesley M. Phillips, and Karen C. Tremba.
section_title: Related GAO Products
paragraphs: 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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