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Date:
07/17/2018
Name:
Fannie Freddie
Organization:
Owner
Rule Number:
Federal Register Citation:
83 FR 33312
CFR:
12 CFR Parts 1206, 1240, and 1750

Comment

Thank you Very much for getting around to putting capital standards out there for Fannie and Freddie. After a Decade of being in conservatorship and running to zero capital, one has to wonder the FHFA intentions & duty as Conservator.

1) will the Companies remain in Conservatorship?
-If so Why would anyone invest in the companies
-If NOT, go to question 2

2) What is to say the companies are not put into Conservatorship again?
-What insurance do the owners have that states they won't be put in Cship again?
-When the companies were forced into conservatorship originally they not only had minimum capital reserves required but also had the highest government officials From FED TREASURY & others all claim they were adequately capitalized.
-So what is to keep them from being forced into conservatorship again?

3) Will the Sweep be Killed? and thus Will the Sr Preferred shares be considered paid in FULL? Will the warrants be valid to be exercised?

4.)Though only having the Power stated under HERA to be a Conservator: preserve & Conserve Companies assets, & the FHFA decided that means it 'MAY' do the exact opposite & perpetually siphon 100% of the companies assets to 1 specific Shareholder(the US TREASURY) thus Voiding Every Other Owner, Which by all means violates the Takings Clause. Why would anyone want to invest in a company that can have its property taken away at any time because FHFA says it 'MAY' give its assets/property to anyone it wants? is there anything from stopping that from happening AGAIN? I know that sounds crazy to even ask but considering it is currently still happening, it seems pretty relevant. 

5.) When the Companies entered Cship, FHFA used accounting write-downs making the losses look much larger than they ever were. This was one of the reasons they had such a profitable year right after implementing the sweep. What is to regulate the regulator stating this Accounting Fraud will NOT happen again? it seems like it could be another run around for the regulator(FHFA) to get the public markets to raise a ton of cash & then throw back into the Treasury's coffers again because of the 'MAY' CONSERVE. 
-To that point IF that happens again, at what point does the FHFA have to say enough is enough and the companies can leave Conservatorship?? after the first billion?, Second Billion dollars? $10Billion? $50B? what about $100Billion? Maybe after $200Billion dollars sent to the treasury you would deem them to be safe solvent companies? because currently the companies are almost up to $300Billion dollars sent to the Treasury & FHFA still hasn't decided these are safe & solvent companies. 
-They are to of the safest consistent companies on the planet- What is is going to take for you to build in a stipulation that says if they do 'whatever parameters you set' they will be released from Conservatorship? Becuase we don't know the NOW, what insurance do we have in the future even if we invest in NEW released companies that we have specific regulations to leave after the next Conservatorship.

Thanks for putting this together,
Capital Framework is a great thing for the Economy, property rights, Government Balance sheet liability, & the Companies Owners,
I sincerely HOPE you Release these Companies ASAP,
As Regulator/Conservator it is 100% your job to release them, NOT congress as you always state, just like it wasn't Congress who implemented the perpetual siphoning of 100% of the companies assets thus voiding all the other owners. 

A decade is far overdue, Government overreach & taking at the largest Scale,

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