Risk-Based Capital

Federal RegisterApr 13, 1999

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SUMMARY: The Office of Federal Housing Enterprise Oversight (OFHEO) is

directed by the Federal Housing Enterprises Financial Safety and

Soundness Act of 1992 to develop a risk-based capital regulation for

Freddie Mac and Fannie Mae (collectively, the Enterprises). The

regulation specifies the risk-based capital stress test that will

determine the amount of capital an Enterprise is required to hold to

maintain positive capital throughout a ten-year period of economic

stress. The results of the risk-based capital stress test will be used

to determine each Enterprise's risk-based capital requirements and,

along with the minimum capital requirement, to determine each

Enterprise's capital classification for purposes of possible

supervisory action.

This Notice of Proposed Rulemaking is the second of two notices of

proposed rulemaking pertaining to the risk-based capital regulation,

both of which respond to comments received on the Advance Notice of

Proposed Rulemaking. The first Notice of Proposed Rulemaking describes

the methodology and rationale OFHEO used to identify the proposed

benchmark loss experience, which is used to determine Enterprise credit

losses during the stress test, and proposes the use of OFHEO's House

Price Index in the stress test. The second Notice of Proposed

Rulemaking specifies the interest rate risk and other components of the

stress test, as well as the overall structure of the test.

DATES: Comments regarding this NPR must be received in writing on or

before August 11, 1999.

ADDRESSES: Send written comments to Anne E. Dewey, General Counsel,

Office of General Counsel, Office of Federal Housing Enterprise

Oversight, 1700 G Street, NW., Fourth Floor, Washington, D.C. 20552.

Written comments may also be sent by electronic mail at

[email protected]

FOR FURTHER INFORMATION CONTACT: Patrick J. Lawler, Director of Policy

Analysis and Chief Economist; David J. Pearl, Director, Office of

Research, Analysis and Capital Standards; or Gary L. Norton, Deputy

General Counsel, Office of General Counsel, Office of Federal Housing

Enterprise Oversight, 1700 G Street, NW., Fourth Floor, Washington,

D.C. 20552, telephone (202) 414-3800 (not a toll-free number). The

telephone number for the Telecommunications Device for the Deaf is

(800) 877-8339.

SUPPLEMENTARY INFORMATION: The Supplementary Information is organized

according to this table of contents:

I. Introduction

A. Background

B. Statutory Requirements for Risk-Based Capital

C. History of the Development of the Regulation

II. Structure and Operation of the Regulation

A. Summary of the Stress Test

1. Introduction

2. Data

3. Stress Test Conditions

4. Mortgage Performance

5. Other Credit Factors

6. Cash Flows

7. Enterprise Operations & Taxes

8. Financial Reporting

9. Calculation of the Risk-based Capital Requirement

B. Sensitivity of Capital Requirement to Risk

1. MBS Guarantees (Sold Loans)

2. Commitments

3. Assets and Liabilities

4. Administrative Costs

5. External Economic Conditions

C. Implications of the Proposed Rule

1. Capital Requirements Under the Proposed Rule

2. Enterprise Adjustments to Meet the Proposed Standard

3. Guarantee Fees

4. Mortgage Interest Rates

III. Issues, Alternatives Considered

A. Mortgage Performance

1. Statutory Requirements

2. Overview of Mortgage Performance

3. Statistical Models of Mortgage Performance

4. General Methodological Issues

5. Default/Prepayment Issues

6. Loss Severity

7. Relating Losses to the Benchmark Loss Experience

8. Inflation Adjustment

B. Interest Rates

1. Yields on Treasury Securities

2. Yields of Non-Treasury Instruments

C. Mortgage Credit Enhancements

1. Background

2. Modeling Approach

3. Comments and Alternatives Considered

D. Liabilities and Derivatives

1. Modeling Methodology

2. Foreign Currency Linked or Unusual Instruments

3. Call and Cancellation Options

4. Counterparty Risk

E. Non-mortgage Investments

F. Other Housing Assets

1. Mortgage Revenue Bonds

2. Private Label REMICs

3. Interests in Partnerships and Joint Ventures

G. Commitments

1. Definition of the Term ``Commitment''

2. Retained vs. Securitized Mortgages

3. Modeling Delivery Percentages

4. Delivery Timing

5. Loan Mix Distribution

6. No New Business Rule

H. New Debt and Investment Rules

1. Rationale for New Debt and New Investment Rules

2. Analysis of ANPR Comments

I. Operating Expenses

J. Dividends and Other Capital Distributions

1. Introduction

2. Statutory Provisions

3. Proposed Approach

4. Analysis of ANPR Comments

K. Other Off-Balance Sheet Guarantees

L. Calculation of the Risk-Based Capital Requirement

1. Proposed Approach to Calculating Capital

2. Justification for Using a Present Value Approach

IV. Technical Supplement

A. Purpose and Scope

B. Single Family Default/Prepayment

1. Introduction

2. Conceptual Framework

3. Data

4. Specification of the Statistical Model

5. Explanatory Variables for Default and Prepayment

6. Empirical Results

7. Application of the Models in the Stress Test

8. Consistency with the Historical Benchmark Experience

9. References

C. Single Family Loss Severity

1. Introduction

2. Conceptual Framework

3. Data

4. Statistical Analysis

5. Consistency with the Benchmark Loss Experience

6. Application to the Stress Test

7. References

D. Multifamily Default/Prepayment

1. Introduction and Conceptual Framework

2. Historical Data

3. Statistical Estimation

4. Explanatory Variables

5. Results of the Statistical Estimation of Default and

Prepayment Equations

6. Application to the Stress Test

7. References

E. Multifamily Loss Severity

1. Introduction

2. Conceptual Framework

3. Sources of Data

4. Data Analysis

5. Application to the Stress Test

6. References

F. Property Valuation

1. Introduction

2. Conceptual Framework

3. Data Sources

4. Statistical Analysis

V. Regulatory Impact

A. Executive Order 12612, Federalism

B. Executive Order 12866, Regulatory Planning and Review

[[Page 18085]]

C. Executive Order 12988, Civil Justice Reform

D. Regulatory Flexibility Act

E. Paperwork Reduction Act

I. Introduction

A. Background

The Office of Federal Housing Enterprise Oversight (OFHEO) was

established by title XIII of the Housing and Community Development Act

of 1992, Pub. L. No. 102-550, known as the Federal Housing Enterprises

Financial Safety and Soundness Act of 1992 (1992 Act). OFHEO is an

independent office within the U.S. Department of Housing and Urban

Development (HUD) with responsibility for ensuring that the Federal

Home Loan Mortgage Corporation (Freddie Mac) and the Federal National

Mortgage Association (Fannie Mae) (collectively, the Enterprises) are

adequately capitalized and operating in a safe and sound manner.

Included among the express statutory authorities of OFHEO's Director

(the Director) is the authority to issue regulations establishing

minimum and risk-based capital standards.\1\

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\1\ 1992 Act, section 1313(b)(1) (12 U.S.C. 4513(b)(1)).

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Fannie Mae and Freddie Mac are Government-sponsored Enterprises

with important public purposes.\2\ These include providing liquidity to

the residential mortgage market and increasing the availability of

mortgage credit benefiting low-and moderate-income families and areas

that are underserved by lending institutions. The Enterprises engage in

two principal businesses: investing in residential mortgages and

guaranteeing securities backed by residential mortgages. The securities

the Enterprises guarantee and the debt instruments they issue are not

backed by the full faith and credit of the United States and nothing in

this document should be construed otherwise.\3\ Yet financial markets

accord the Enterprises' securities preferential treatment relative to

securities issued by potentially higher-capitalized, fully private, but

otherwise comparable firms. The market prices for Enterprise debt and

mortgage-backed securities, and the fact that the market does not

require that those securities be rated by a national rating agency,

suggest that investors perceive that the government implicitly

guarantees those securities. This perception evidently arises from the

public purposes of the Enterprises, their Congressional charters, their

potential direct access to U.S. Department of Treasury (Treasury)

funds, and the statutory exemptions of their debt and mortgage-backed

securities (MBS) from otherwise mandatory investor protection

provisions.\4\

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\2\ 1992 Act, sections 1331-38 (12 U.S.C. 4561-67, 4562 note).

\3\ See, Federal Home Loan Mortgage Corporation Act, section

306(h)(2) (12 U.S.C. 1455(h)(2)); Federal National Mortgage

Association Charter Act, section 304(b) (12 U.S.C. 1719(b)); and

1992 Act, section 1302(4) (12 U.S.C. 4501(4)).

\4\ See, e.g., 12 U.S.C. 24 (authorizing unlimited investment by

national banks in obligations of or issued by the Enterprises); 12

U.S.C. 1455(g), 1719(d), 1723(c) (exempting securities from

oversight from Federal regulators); 15 U.S.C. 77r-1(a) (preempting

State law that would treat Enterprise securities differently from

obligations of the United States for investment purposes); 15 U.S.C.

77r-1(c) (exempting Enterprise securities from State blue sky laws).

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Congress created OFHEO as the safety and soundness regulator of the

Enterprises to reduce their risk of failure. Although each Enterprise

at the time had experienced profitability and sustained growth,

Congress determined that there was a need for a strong and independent

regulator to promote the capital adequacy of the Enterprises. This

determination was grounded in the recognition of many factors,

including (1) the important public purpose served by the Enterprises in

the secondary market for residential mortgages, and (2) the

Enterprises' important role in providing access to mortgage credit in

central cities, rural regions, and underserved areas.

Another important factor leading to OFHEO's creation was the

recognition that the Enterprises are largely insulated from private

market discipline relative to fully private firms. This insulation

results from the apparent investor perception of an implied guarantee,

and is best exemplified by the market's acceptance of Fannie Mae

securities in the early 1980s and the Farm Credit System's securities

in the mid-1980s when these GSEs were experiencing financial

difficulties. The absence of normal market discipline on risk-taking is

a strong argument for effective government regulation, including

capital regulation.

Congress was also concerned about the serious disruptions to the

nation's housing markets that could result from an Enterprise's

failure. In introducing legislation in the House of Representatives,

then House Banking Committee Chairman Henry Gonzalez noted that--

The savings and loan crisis and the large losses incurred by the

Federal Government to resolve the crisis, raises concerns about the

scope of other potential liabilities of the United States, including

the liabilities of Fannie Mae, Freddie Mac, and the [Federal Home

Loan] banks. These entities are privately owned federally chartered

enterprises established to meet certain credit needs. Together they

have more than $800 billion in mortgage-related liabilities.\5\

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\5\ Comments by Rep. Gonzalez upon introducing H.R. 2900, 137

Cong. Rec. H5497 (July 16, 1991).

In expressing his view that the legislation did not go far enough

to ensure the Enterprises' safety and soundness, then Ranking Minority

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Member Jim Leach stated that--

If there is a singular lesson of the 1980's, it is that

prudential capital ratios are critical not only for providing a

cushion between an institution's liabilities and the taxpayer's

pocket book, but they ground institutional decision-making in less

risky behavior. Where there is minimal private capital at risk there

is always an inordinate incentive to bet the bank on speculative

investments or interest rate moves. And perhaps most consequently,

capital ratios determine constraints on growth. If institutions are

allowed 50 or 100 to 1 leveraging, as occurred so recently in the

thrift industry, imprudent or conflict driven decision making can

too quickly cause disproportionate growth in certain institutions,

industries and parts of the country, with the taxpayer on the line

for management stupidity, foul play or bad luck.

Fortunately, both GSEs are well run today. Fannie, in particular

has been a major market winner as the cost of funds has declined

with more restrained levels of inflation. But Congress must

understand that if interest rates had gone up rather than down in

the 1980's, Fannie Mae would be the single largest institutional

liability the U.S. government would ever have been forced to

oversee.\6\

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\6\ Dissenting views of Rep. Leach, Government-Sponsored Housing

Enterprises Financial Safety and Soundness Act of 1991, H.R. Rep.

No. 102-206 on H.R. 2900, at 114 (1991) (House Report).

Similarly, the Senate Report \7\ stated that--

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\7\ Federal Housing Enterprises Regulatory Reform Act of 1992,

S. Rep. No. 102-282 (1992) (Senate Report).

Past performance indicates that [the risks of an Enterprise's

failure] are not just hypothetical. While both GSEs are currently

very prosperous, HUD estimated in a 1986 report to Congress, that

Fannie Mae was insolvent on a marked-to-market basis at year-end

1978 and did not return to solvency until 1985. Its negative net

worth reached a peak of more than $20 billion in 1981, which was

roughly 20 percent of its outstanding liabilities. Its recovery owed

partly to improved management, but also, in considerable measure to

fortuitous declines in interest rates.\8\

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\8\ S. Rep. No. 102-282, at 10 (1992).

Because of Congress' concerns, OFHEO was established as the safety

and soundness regulator of Fannie Mae and Freddie Mac. OFHEO is

responsible for conducting examinations to ensure the Enterprises'

safety and soundness and establishing and enforcing compliance with two

types of capital

[[Page 18086]]

standards required by the 1992 Act. The first is the minimum capital

standard.\9\ Using this standard, which is based on a set of leverage

ratios, OFHEO has classified each Enterprise's capital position every

quarter since OFHEO's inception. After initially using an interim

procedure, OFHEO published a rule regarding minimum capital, which

incorporates a more careful evaluation of the credit risks associated

with swaps and other off-balance sheet obligations.\10\ The resulting

standard is comparable in its construction to the risk-based capital

standards of other financial institution regulators.

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\9\ 1992 Act, section 1362 (12 U.S.C. 4612).

\10\ 12 CFR 1750.4; see Minimum Capital, Final Rule, 61 FR

35607, July 8, 1996.

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The second capital standard required by the 1992 Act is the risk-

based capital standard. This standard requires each Enterprise to hold

sufficient capital to survive a ten-year period characterized by

adverse credit losses and large movements in interest rates, plus an

additional amount to cover management and operations risk.\11\ The

level of capital \12\ required under this standard for an Enterprise

will reflect that Enterprise's specific risk profile at the beginning

of each quarter for which the stress test will be run.

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\11\ 1992 Act, section 1361 (12 U.S.C. 4611).

\12\ For purposes of the risk-based capital standard, the term

``capital'' means ``total capital'' as defined under section

1303(18) of the 1992 Act (12 U.S.C. 4502(18)) to mean the sum of the

following:

(A) The core capital of the enterprise;

(B) A general allowance for foreclosure losses, which--

(i) shall include an allowance for portfolio mortgage losses, an

allowance for nonreimbursable foreclosure costs on government

claims, and an allowance for liabilities reflected on the balance

sheet for the enterprise for estimated foreclosure losses on

mortgage-backed securities; and

(ii) shall not include any reserves of the enterprise made or

held against specific assets.

(C) Any other amounts from sources of funds available to absorb

losses incurred by the enterprise, that the Director by regulation

determines are appropriate to include in determining total capital.

The term ``core capital'' is defined under section 1303(4) of

the 1992 Act (12 U.S.C. 4502(4)) to mean the sum of the following

(as determined in accordance with generally accepted accounting

principles):

(A) The par or stated value of outstanding common stock.

(B) The par or stated value of outstanding perpetual,

noncumulative preferred stock.

(C) Paid-in capital.

(D) Retained earnings.

The core capital of an enterprise shall not include any amounts

that the enterprise could be required to pay, at the option of

investors, to retire capital instruments.

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The risk-based standard is an essential component of the safety and

soundness regulation of the Enterprises. Without the risk-based

standard, an Enterprise might adopt risk positions of sufficient

magnitude to make a capital level that just meets the minimum standard

inadequate for maintaining a safe and sound financial condition.

However, the risk-based standard cannot, by itself, ensure

sufficient capital to meet all contingencies. While the interest rate

and credit stresses that are incorporated in the stress test, as

specified by statute, are historically unprecedented, future economic

environments may be even more adverse. Additionally, the nature of

actual future stresses may differ from the precise stresses

incorporated in the model. Furthermore, the model contains factors such

as mortgage default and prepayment rates that are based on historical

experience and therefore may be less adverse than those actually

occurring in future economic environments. Similarly, the consequences

of risks other than interest rate and credit risks may also prove more

serious than the fixed proportional amount allowed for management and

operations risk.

In addition to the risk-based standard, there is a minimum capital

standard, which requires that in the absence of large measurable risks,

the Enterprise maintain a minimally acceptable level of capital.

Complementing the two capital standards are OFHEO's examination and

enforcement authorities, which provide the knowledge and authority

necessary to require prudent management practices in all environments.

All of these regulatory mechanisms operate in tandem to promote the

safety and soundness of the Enterprises.

B. Statutory Requirements for Risk-Based Capital

The 1992 Act requires that OFHEO, by regulation, establish a risk-

based capital test (known as the stress test) which, when applied to an

Enterprise, shall determine that amount of total capital for the

Enterprise that is sufficient for the Enterprise to maintain positive

capital during the stress period. The 1992 Act also provides that, in

order to meet its risk-based capital standard, each Enterprise is

required to maintain an additional 30 percent of this amount to protect

against management and operations risk.\13\

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\13\ 1992 Act, section 1361(c)(2) (12 U.S.C. 4611(c)(2)).

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The 1992 Act requires that the stress test subject each Enterprise

to large credit losses on mortgages it owns or guarantees. The

frequency and severity of those losses must be reasonably related to

the highest rates of default and severity of mortgage losses

experienced during a period of at least two consecutive years in

contiguous areas of the United States that together contain at least

five percent of the total U.S. population.\14\ OFHEO is required to

identify what it has characterized as the ``benchmark loss experience''

that resulted in the highest loss rate.\15\ In this context, default

and severity behavior means the frequency, timing, and severity of

losses on mortgage loans, given the specific characteristics of those

loans and the economic circumstances affecting those losses.

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\14\ 1992 Act, section 1361(a)(1) (12 U.S.C. 4611(a)(1)).

\15\ In this document, the word ``benchmark,'' when used as an

adjective or a noun, refers to the benchmark loss experience.

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The 1992 Act also prescribes two interest rate scenarios, one with

rates falling and the other with rates rising.\16\ The risk-based

capital amount is based on whichever scenario would require more

capital for the Enterprise. In prescribing the two scenarios, the 1992

Act describes the path of the ten-year constant maturity yield (CMT)

for each scenario and directs OFHEO to establish the yields on Treasury

instruments of other maturities in a manner reasonably related to

historical experience and judged reasonable by the Director.

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\16\ 1992 Act, section 1361(a)(2) (12 U.S.C. 4611(a)(2)).

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In the falling or down-rate scenario, the ten-year CMT decreases

during the first year of the stress period and then remains constant at

the lesser of (a) 600 basis points below the average yield during the

nine months preceding the stress period or (b) 60 percent of the

average yield during the three years preceding the stress period.

However, the 1992 Act limits the decrease in yield to 50 percent of the

average yield in the nine months preceding the stress period.\17\

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\17\ 1992 Act, section 1361(a)(2)(B) (12 U.S.C. 4611(a)(2)(B)).

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In the rising or up-rate scenario, the ten-year CMT increases

during the first year of the stress period and then remains constant at

the greater of (a) 600 basis points above the average yield during the

nine months preceding the stress period or (b) 160 percent of the

average yield during the three years preceding the stress period.

However, the 1992 Act limits the increase in yield to 175 percent of

the average yield over the nine months preceding the stress period.\18\

The 1992 Act recognizes that interest rates can affect credit risk,

specifically requiring that credit losses be adjusted for a

correspondingly higher rate of general price inflation if

[[Page 18087]]

application of the stress test produces an increase of more than 50

percent in the ten-year CMT.\19\

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\18\ 1992 Act, section 1361(a)(2)(C) (12 U.S.C. 4611(a)(2)(C)).

\19\ 1992 Act, section 1361(a)(2)(E) (12 U.S.C. 4611(a)(2)(E)).

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The Act requires that the stress test take into account

distinctions among mortgage product types and differences in seasoning.

It may also take into account any other factors that the Director deems

appropriate. The 1992 Act does not require a specific adjustment for

any of these factors, allowing the Director to determine how best to

account for them. Likewise, the 1992 Act requires the Director to

determine losses and gains on Enterprise activities not specifically

addressed, and all other characteristics of the stress test not

explicitly defined in the 1992 Act, on the basis of available

information, in a manner consistent with the stress test.\20\ These

stress test characteristics could include, among others, mortgage

prepayment rates and Enterprise funding activities, operating expenses,

and capital distribution activities.

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\20\ 1992 Act, sections 1361(b) and (d)(2) (12 U.S.C. 4611(b)

and (d)(2)).

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The 1992 Act requires the stress test to provide initially that

each Enterprise will conduct no new business within the stress period,

except to fulfill contractual commitments to purchase mortgages or

issue securities. Four years after the final risk-based capital

regulation is issued, OFHEO is authorized to modify the stress test to

incorporate assumptions about additional new business conducted during

the stress period.\21\ In doing so, OFHEO is required to take into

consideration the results of studies conducted by the Congressional

Budget Office and the Comptroller General of the United States on the

advisability and appropriate forms of new business assumptions. The

1992 Act requires that the studies be completed within the first year

after issuance of the final regulation.\22\

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\21\ 1992 Act, sections 1361(a)(3)(B) and (D) (12 U.S.C.

4611(a)(3)(B) and (D)).

\22\ 1992 Act, section 1361(a)(3)(C) (12 U.S.C. 4611(a)(3)(C)).

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In developing this proposal, OFHEO considered whether it would be

permissible and appropriate not to propose a detailed risk model, and

instead to rely on the risk models developed by the Enterprises

themselves.\23\ Under such a regulatory approach, OFHEO would specify

only the basic interest rate and credit assumptions, rely on the

Enterprises' internal modeling of these scenarios and review those

models and the results.

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\23\ This approach, which OFHEO considered in detail as it began

to develop the risk-based capital regulation, was raised most

recently by Fannie Mae during the OMB review process. See the

letters from Ms. Jamie S. Gorelick, Vice Chair, Fannie Mae of

December 4, 1998 to various OMB officials; and of March 10, 1999, to

Dr. Janet Yellen, Chair, Council of Economic Advisers.

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OFHEO has thoroughly considered this approach and believes that it

would not be consistent with the 1992 Act, which anticipates that a

publicly-available, transparent and reproducible test would be applied

to the Enterprises. The 1992 Act provides for both Enterprises to be

subject to the same stress test; \24\ that the full test be subject to

notice and comment rulemaking; \25\ that the risk-based capital

regulation be sufficiently specific to permit anyone to apply the test,

given relevant Enterprise data; \26\ and that OFHEO must make the

stress test model public.\27\ Relying on the Enterprises to compute

their own capital requirements with their proprietary models would be

inconsistent with all of these provisions.

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\24\ See 12 U.S.C. 4611(a) (``The Director shall, by regulation,

establish a risk-based capital test for the Enterprises. When

applied to an Enterprise, the risk-based capital test shall

determine the amount of total capital for the Enterprise . . .'')

(emphasis added). See also H.R. Rep. No. 102-206 at 62 (1991).

(``Beyond these traditional capital ratios, the bill sets forth

guidelines for the creation, in highly specific regulations, of a

risk-based capital standard . . . The model, or stress test, will

generate a number for each Enterprise, which will become the risk-

based standard for that Enterprise.'') (emphasis added).

\25\ Section 1361(e)(1), 12 U.S.C. 4611(e)(1).

\26\ Section 1361(e)(2), 12 U.S.C. 4611(e)(2).

\27\ Section 1361(f), 12 U.S.C. 4611(f).

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Moreover, a rule that specifies the details of the model will

provide a more consistent and effective capital regulation and will not

place undue burdens on the Enterprises. The structure of OFHEO's

regulatory and enforcement authorities presumes a strong risk-based

capital standard. The level of the minimum (leverage) capital standard

was established with the assumption that there would be a meaningful

risk-based standard that would address actual or potential risk not

addressed by simple leverage ratios. In addition, important OFHEO

enforcement authorities are tied to the risk-based capital requirement.

An Enterprise's failure to meet these requirements triggers two

important enforcement authorities: the ability to reduce or eliminate

the Enterprise's dividends and the ability to require a capital

restoration plan acceptable to OFHEO. Also, the grounds for a cease and

desist action vary depending on whether an Enterprise meets the risk-

based standard. Thus, a weaker standard would weaken OFHEO's

enforcement authorities.

These objectives are best obtained by a clear standard that is

presented to the public for comment and then employed consistently to

evaluate both Enterprises. Reliance instead on Enterprise models would

likely result in a weaker inconsistently-applied standard. Use of

Enterprise models would give the Enterprises broad discretion to

determine their own risk-based capital requirements because stress test

details beyond basic assumptions and modeling techniques can have a

substantial cumulative effect on the results. Existing market

distortions would give the Enterprises incentives to adjust those

details to produce low requirements.

The Enterprises' status as government-sponsored-enterprises

attenuates market discipline of Enterprise capital levels. The

Enterprises are highly leveraged financial institutions. Fully private

firms that depend heavily on debt markets are inhibited from taking on

large amounts of risk relative to their equity capital. Interest rates

on debt or guaranteed securities are sensitive to the perceived credit

quality of the issuers or guarantors. However, because investors treat

Enterprise obligations as implicitly guaranteed by the Federal

government, the normal linkage between the adequacy of an Enterprise's

capital and the interest rates on its obligations is severed. Thus,

because of the perceived implicit guarantee, the Enterprises have an

incentive to hold less capital, relative to their risk levels, than

they would if their debt costs were subject to normal market forces. A

strong risk-based capital standard can address this distortion, but the

Enterprises have little incentive to assist in producing such a result.

Reliance on different Enterprise internal models would also result

in unequal treatment. The nature of business risks and risk management

techniques are very similar at the two Enterprises. It is most

appropriate and most fair to determine each Enterprise's capital

adequacy in the same way. However, capital models developed by the two

Enterprises would likely differ significantly. Differences in resulting

standards could easily mask significant differences in true capital

adequacy between the Enterprises. Furthermore, a lower effective

standard at one Enterprise could give that Enterprise important

business advantages over the other. The resulting competitive pressures

would give the Enterprise with the higher standard an incentive to

conform with the lower standard.

A model fully specified in regulation and administered by OFHEO, on

the other hand, does not suffer these disadvantages. Such a model is

feasible

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because OFHEO regulates only two institutions, with similar risks and

relatively narrow lines of business. The transparency of this approach

allows all interested parties to comment meaningfully on the precise

method of determining Enterprise capital requirements, and it gives the

Enterprises the ability to internalize the model for planning purposes.

In analyzing this issue, OFHEO is aware that some Federal financial

institution regulators make limited use of internal models. However,

those uses of internal models are made in very different circumstances

and by regulators with different authorizing statutes. Many of the

institutions in which these regulators rely upon internal models are

exposed to substantial market discipline of their capital and risk

positions because they rely heavily on uninsured liabilities. Such

discipline effectively forces large banks to hold capital well in

excess of regulatory requirements.

Even in these circumstances, other regulators depend on internal

models only to a small extent as a supplement to other measures of

capital adequacy. Bank capital requirements are primarily based on

overall or risk-weighted ratios that are substantially higher than

those applied to the Enterprises under the minimum capital standard. To

supplement those ratios, regulators require banks with significant

market risk exposures (those that have large trading accounts) to use

their internal value-at-risk models to calculate a market-risk capital

component of their overall risk-based capital requirements. However,

partly because of the uncertainties surrounding model construction and

verification, bank regulators require a multiple of three or more times

the amount of capital for market risk exposures that the internal

models estimate.\28\ This limited use of internal models in very

different circumstances does not appear applicable to Enterprise

capital regulation.

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\28\ See, for example, Darryll Hendricks and Beverly Hirtle,

``Bank Capital Requirements for Market Risk: The Internal Models

Approach,'' in Economic Policy Review, Federal Reserve Bank of New

York, December 1997, pp. 3-6.

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OFHEO considered whether an internal models approach could permit

greater flexibility and innovation by the Enterprises, because they

could modify their internal risk models at will. OFHEO believes the

issues of flexibility and innovation have been appropriately addressed

in the proposed regulation. In general, OFHEO expects that credit and

interest rate risk of new Enterprise activities and instruments will be

reflected in the stress test by simulating their credit and cash flow

characteristics using the approaches described in the regulation. OFHEO

will provide the Enterprises with its estimate of the capital treatment

of new products, investments or instruments as soon as possible after

the Enterprises notify OFHEO of the new activities. In addition, OFHEO

will monitor the Enterprises' activities and, when appropriate, propose

amendments to this regulation addressing the treatment of new

instruments and activities.

For all the reasons described, OFHEO believes that the approach

proposed in this Notice implements the requirement of the 1992 Act and

provides an appropriate means for ensuring the capital adequacy of the

Enterprises. In accordance with the requirements of the Administrative

Procedure Act, OFHEO is requesting comments on all of the issues raised

in this Notice of Proposed Rulemaking.

C. History of the Development of the Regulation

OFHEO's mission is to ensure that the Enterprises are adequately

capitalized and operating in a safe and sound manner. The principal

objective of the risk-based capital standard is to reduce the risk of

Enterprise insolvency. Another important objective of the risk-based

capital standard is to align the incentives reflected in the regulatory

capital requirement with the incentives of prudent risk management. The

ultimate goal is for the Enterprises to maintain the financial health

necessary to fulfill their public purposes. Although the stress test

produces a single capital requirement, it effectively creates

incremental regulatory capital requirements for each additional dollar

of business for every product type an Enterprise guarantees or holds in

portfolio. Marginal capital requirements for mortgages held in

portfolio will vary depending on the risk inherent in an Enterprise's

funding strategy.

OFHEO designed the stress test so that the incentives it creates

closely reflect the relative risks inherent in the Enterprises'

different activities. To this end, the proposed regulation

incorporates, to the extent feasible, consistent relationships between

the economic environment of the stress period and the Enterprises'

businesses. Doing so required OFHEO to model the Enterprises' assets,

liabilities, and off-balance sheet positions at a sufficient level of

detail to capture important risk characteristics.

However, as the level of detail of the stress test increased, so

did its complexity, along with the time and other resources that were

required to develop it. OFHEO also faced certain practical limits to

the number of variables that could be modeled due to the limitations of

existing data. Therefore, in developing this proposed regulation, OFHEO

sought to achieve a level of complexity and realism in the stress test

that appropriately balanced the associated benefits and costs.

OFHEO's stress test is comprised of a number of components, some

that correspond to subjects specifically cited in the 1992 Act and

others that represent the infrastructure that makes the stress test

operational. Figure 1 illustrates these components and their

interrelationships. The infrastructure components--database, cash

flows, and financial reports--are shaded gray. The unshaded components

implement the specific requirements of the 1992 Act, as well as the

many other aspects of the stress test that the 1992 Act either requires

or permits OFHEO to determine.

[[Page 18089]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.369

On February 8, 1995, OFHEO published an Advance Notice of Proposed

Rulemaking (ANPR) \29\ as its first step in developing the risk-based

capital regulation. The ANPR announced OFHEO's intention to develop and

publish a risk-based capital regulation and solicited public comment on

issues relating to that regulation.

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\29\ Risk-Based Capital, ANPR, 60 FR 7468, February 8, 1995.

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The comment period for the ANPR ended on May 9, 1995, and was

extended through June 8, 1995.\30\ OFHEO received 17 comments on the

ANPR from a variety of interested parties. Commenters included two

Executive Branch Departments, HUD and Department of Veterans Affairs

(VA); one Federal financial institution regulatory agency Office of

Thrift Supervision (OTS); one Federal regulatory agency, U.S. Commodity

Futures Trading Commission (CFTC); the Enterprises, Fannie Mae and

Freddie Mac; four trade groups, Mortgage Bankers Association of America

(MBA), America's Community Bankers (ACB), National Association of

Realtors (NAR), and Mortgage Insurance Companies of America (MICA); two

mortgage banking firms, PNC Mortgage Corporation of America and Norwest

Mortgage, Inc.), one rating agency Standard and Poor's Ratings Group

(S&P); one thrift institution, World Savings and Loan Association

(MS&L); one private mortgage research firm, Mortgage Risk Assessment

Corporation (MRAC); and one individual, Professor Anthony Yezer of

George Washington University. The responses to the ANPR ranged from a

comment on only one or two specific risk-based capital issues to an

extensive analysis of every question or issue raised. OFHEO has

considered these comments in the development of its risk-based capital

regulation.

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\30\ Risk-Based Capital, Extension of Public Comment Period for

ANPR, 60 FR 25174, May 11, 1995.

---------------------------------------------------------------------------

OFHEO determined that the scope of the regulatory project required

the issuance of two separate Notices of Proposed Rulemaking (NPR), each

addressing different components of the stress test. On June 11, 1996,

OFHEO published a Notice of Proposed Rulemaking (NPR1),\31\ which

addresses two components. The first component is the methodology for

identifying and measuring the benchmark loss experience, which provides

the basis for determining credit losses that the Enterprises will

experience during the stress period. The second is OFHEO's proposal to

use the OFHEO House Price Index (HPI), which is a weighted repeat

transactions house price index, rather than the Constant Quality Home

Price Index (CQHPI) published by the Secretary of Commerce, to measure

differences in seasoning of single family mortgages in the stress

test.\32\ NPR1 included OFHEO's responses to all of the ANPR comments

that related to those two areas. The comment period for NPR1 ended on

September 9, 1996, and was extended through October 24, 1996.\33\ OFHEO

received 11 written comments on NPR1 and will consider and respond to

those in the final risk-based capital regulation.

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\31\ Risk-Based Capital, NPR1, 61 FR 29592, June 11, 1996.

\32\ 61 FR 29616, June 11, 1996.

\33\ Risk-Based Capital, Extension of Public Comment Period for

NPR, 61 FR 42824, August 19, 1996.

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This Notice of Proposed Rulemaking (NPR2) specifies and proposes

for public comment all of the remaining aspects of the risk-based

capital stress test not covered in NPR1. The notice includes an

overview of the stress test, the stress test's sensitivity to risk, the

implications of the stress test for the Enterprises, and specific

issues related to the stress test. Among the specific issues discussed

are mortgage performance (i.e., default, prepayment, and loss

severity), interest rates, new debt and new investments, commitments,

dividends and other

[[Page 18090]]

capital distributions, operating expenses, credit enhancements,

liabilities and derivatives, non-mortgage investments, and capital

calculation. The notice also includes a technical supplement that

explains the derivation of equations used in the stress test. Finally

the notice contains the regulatory text which includes the regulatory

appendix that provides the technical details of the regulation.

OFHEO believes that it is important for this proposal to receive

full public review and comment. Accordingly, OFHEO invites all

interested parties to comment on the issues raised in this NPR. OFHEO

will consider comments received, together with those received on NPR1,

in the development of the final risk-based capital regulation.

II. Structure and Operation of the Regulation

A. Summary of the Stress Test

1. Introduction

OFHEO's risk-based capital regulation is part of a larger

regulatory framework for the Enterprises that includes a minimum

capital requirement and a comprehensive examination program. The

purpose of this regulatory framework is to reduce the risk of failure

of the Enterprises by ensuring that the Enterprises are adequately

capitalized and operating safely, in accordance with the 1992 Act.

OFHEO's risk-based capital requirement differs from the minimum

capital requirement by relating the required capital to the risk in an

Enterprise's financial activities. In order to determine risk-based

capital for the Enterprises, OFHEO has been charged with creating a

stress test that simulates the effects of ten years of adverse economic

conditions on the existing assets and obligations of the Enterprises.

Both the minimum and the risk-based capital requirements work in

conjunction with OFHEO's examination program to ensure that the

Enterprises are adequately capitalized and operating safely.

In creating the proposed stress test, OFHEO had to ensure that it

met all the statutory requirements outlined in the 1992 Act and that it

accurately and appropriately captured the risks related to the business

of the Enterprises. To accomplish this, OFHEO modeled both sides of the

Enterprises' balance sheets, as well as their off-balance sheet

obligations, at the level of detail necessary to capture the risk

involved. In selecting among alternative approaches, OFHEO sought to

minimize the possibility of perverse incentives in the stress test. The

regulation was designed to ensure that stresses were appropriate in

order to promote safety and soundness and ensure the Enterprises'

ability to fulfill their important public missions.

The stress test determines, as of a point in time, how much capital

an Enterprise requires to survive the economically stressful conditions

outlined by the 1992 Act. At a minimum, the stress test would be run on

a quarterly basis. The stress test takes as inputs data on an

Enterprise's assets and obligations, operations, interest rates, and

the housing market. These data are used in econometric, financial, and

accounting models to simulate Enterprise financial performance over a

ten year period called the ``stress period.'' The stress test then

computes the amount of starting capital that would permit an Enterprise

to maintain a positive capital position throughout the stress period.

To determine the risk-based capital requirement, the 1992 Act requires

that 30 percent of this amount is added to cover management and

operations risk.

This summary provides a high level description of the stress test.

For a more detailed description, refer to the Regulation Appendix. For

explanations of the reasons for the approaches taken, refer to section

III., Issues, Alternatives Considered. For detailed information on

econometric models and historical property valuation-related indexes

used in the stress test, refer to section IV., Technical Supplement.

Throughout the summary, it may be helpful to refer to the stress test

diagram, in section I., Introduction.

2. Data

The stress test utilizes data characterizing at a point in time an

Enterprise's assets, liabilities, and off-balance sheet obligations, as

well as data on economic conditions. The Enterprises submit data to

OFHEO for mortgages, securities, and derivative contracts at the

instrument level, that is, for individual mortgages, securities, and

contracts. OFHEO obtains data on economic conditions from public

sources. All these data are referred to as ``starting position data''

for the date for which the stress test is run.

For modeling efficiency, the stress test aggregates loans into

groups of loans with common risk and cash flow characteristics (``loan

groups''). For instance, 30-year fixed-rate mortgages for single family

homes in the same geographic region, originated in the same year, with

similar interest rates and LTVs,\34\ and held in an Enterprise's

portfolio, are grouped together in one loan group. In this way, over 24

million loans are aggregated into the minimum number of loan groups

that captures important risk characteristics. These loan groups,

instead of individual loans, are then used as inputs by the mortgage

performance and cash flow components of the stress test.

---------------------------------------------------------------------------

\34\ LTV is the loan to value ratio, which is the loan balance

divided by the value of the property securing the loan.

---------------------------------------------------------------------------

In addition to starting position data for existing loans, the

stress test creates loan group data for the new mortgages that will be

added during the stress test. The 1992 Act requires that the stress

test simulate the fulfillment of the Enterprises' contractual

commitments, outstanding at the start of the stress period, to purchase

and/or securitize mortgages. The new mortgages that the stress test

adds consist of four single family loan product types: 30-year fixed-

rate, 15-year fixed-rate, adjustable-rate, and balloon. The percentage

of each type added is based on the relative proportions of those types

of loans securitized by an Enterprise that were originated during the

six months preceding the start of the stress period. The mix of LTV,

region, guarantee fee, and other characteristics of these new loans

also reflects the characteristics of the loans originated during the

preceding six months. All new mortgages are securitized. In the down-

rate scenario, 100 percent of these loans are added during the first

three months of the stress period; in the up-rate scenario, 75 percent

of these loans are added during the first six months. These loan groups

are then treated like the loan groups created for loans on the

Enterprise's books at the start of the stress period.

Because of the smaller number and greater diversity of the

Enterprises' non-mortgage financial instruments (investments and debt),

the stress test projects these cash flows at the individual instrument

level, rather than at a grouped level. Data used for these projections

include the instrument characteristics that are used to model

securities, both investment and debt, as well as derivative contracts.

3. Stress Test Conditions

a. Benchmark Loss Experience

In NPR1, OFHEO proposed the methodology for identifying the

benchmark loss experience, the stressful credit conditions which are

the basis for credit losses in the stress test. With this methodology,

OFHEO identified the worst cumulative credit losses

[[Page 18091]]

experienced by loans originated during a period of at least two

consecutive years, in contiguous states encompassing at least five

percent of the U.S. population. The performance of these loans (i.e.,

the frequency, timing and severity of their losses) and the related

interest rate and housing market environment, comprise the benchmark

loss experience.

The benchmark loss experience is based on newly originated, 30-

year, fixed-rate, first lien mortgages on owner-occupied, single family

properties. The performance of these benchmark loans was a function of

their original LTVs and other characteristics, as well as the specific

house price and interest rate paths they experienced. The stress test

applies the path of house prices from the benchmark loss experience and

the interest rate paths required by the 1992 Act. Furthermore, the

stress test simulates the performance of an Enterprise's entire

mortgage portfolio, including loans of all types, ages, and

characteristics. Primarily for these reasons, overall Enterprise

mortgage loss rates in the stress test are much lower than the loss

rates OFHEO reported in NPR1 for benchmark loans.

When the mortgage performance models are applied to benchmark

loans, using the benchmark pattern of interest rates, losses are very

close to those identified in NPR1. The remaining difference results

from the fact that OFHEO based its mortgage performance models on all

Enterprise historical loan data, not just the limited data for

benchmark loans, and that the benchmark loss experience was

particularly severe. This difference is corrected by calibrating the

single family mortgage performance models, resulting in slight upward

adjustments of default and loss severity rates, so that they are

consistent with the benchmark loss experience.

For multifamily loans, the stress test also incorporates patterns

of vacancy rates and rent growth rates that are consistent with the

benchmark loss experience. In this manner, the stress test relates the

performance of multifamily loans to the benchmark loss experience.

b. Interest Rates

Interest rates are a key component of the adverse economic

conditions of the stress test. The 1992 Act specifies two scenarios for

the ten-year Constant Maturity Treasury yield (CMT) during the stress

period. During the first year of the stress period, the ten-year CMT:

falls by the lesser of 600 basis points below the average

yield during the nine months preceding the stress period, or 60 percent

of the average yield during the three years preceding the stress

period, but in no case to a yield less than 50 percent of the average

yield during the preceding nine months (down-rate scenario); or

rises by the greater of 600 basis points above the average

yield during the nine months preceding the stress period, or 160

percent of the average yield during the three years preceding the

stress period, but in no case to a yield greater than 175 percent of

the average yield during the preceding nine months (up-rate scenario).

Changes to the ten-year CMT occur in twelve equal monthly

increments from the starting point for the ten-year CMT, which is the

average of the daily yields for the month preceding the stress period.

The ten-year CMT stays at the new level for the remainder of the stress

period.

The stress test establishes the Treasury yield curve for the stress

period in relation to the prescribed movements in the ten-year CMT. In

the down-rate scenario the yield curve is upward sloping during the

last nine years of the stress period. In the up-rate scenario the

Treasury yield curve is flat for the last nine years of the stress

period, that is, yields of other maturities are equal to that of the

ten-year CMT.

Because many different interest rates affect the Enterprises'

business performance, the ten-year CMT and the Treasury yield curve are

not the only interest rates that must be determined. For example,

current mortgage rates affect rates of refinancing of existing

mortgages; adjustable-rate mortgages periodically adjust according to

various indexes; floating rate securities (assets and liabilities) and

many rates associated with derivative contracts also adjust; and

appropriate yields must be established for new debt and investments.

Thus, the stress test requires rates and indexes other than Treasury

yields for the entire period of the stress test. Some of the key rates

that are estimated are the Federal Funds rate, London Inter-Bank

Offered Rate (LIBOR), Federal Home Loan Bank 11th District Cost of

Funds Index (COFI), and Enterprise borrowing rates. The stress test

establishes these rates and indexes by using Autoregressive Integrated

Moving Average (ARIMA) procedures--time-series estimation techniques--

to estimate their values based on historical spreads to yields on

Treasuries of comparable maturities. The procedures use historical

information to estimate values during the stress period. To reflect the

market impact of stress test economic conditions on the Enterprises'

costs of borrowing, beginning in the second year of the stress period,

50 basis points are added to the computed yields for Enterprise debt

securities.

c. Property Values

In determining the performance (rates of default, prepayment, and

of loss severity) of an Enterprise's mortgages in the stress test, the

1992 Act requires OFHEO to consider seasoning, which the stress test

captures by the use of current LTVs. The stress test calculates the

numerator of current LTV, the current loan balance, based on the unpaid

principal balance of the loan at the start of the stress period

(starting UPB) and the amortization of the loan based on product type.

Both the starting UPB and the loan product type are included in

starting position data. The stress test uses the OFHEO HPI for the

relevant Census division to track changes in property values--the

denominator of current LTV--from the time of loan origination through

to the start of the stress period. During the stress period, changes in

property values are computed by applying the pattern of house price

changes from the benchmark loss experience.

The HPI values represent average property value appreciation. In

simulating mortgage performance, the stress test also captures

variations from average house price movements, called dispersion. For

this purpose, the stress test uses the mathematical measures of

dispersion that OFHEO publishes along with the HPI.

For multifamily properties, property values are derived from

estimates of a property's net operating income and capitalization rate

multipliers. The stress test uses loan data together with rent growth

rate and vacancy rate indexes to derive estimates of net operating

income (NOI) for multifamily loans. Index values from the benchmark

loss experience are applied to starting property values to derive

current estimates of NOI for each month of the stress period. NOI is

multiplied by a capitalization rate multiplier, reflecting current

interest rates, to generate a property value. For example, if annual

NOI is $200,000 and the capitalization rate multiplier is ten, the

property value is $200,000 x 10, or $2,000,000. This value is the

denominator for current LTV for multifamily loans.

When the ten-year CMT increases by more than 50 percent over the

average yield during the nine months preceding the stress period, the

stress test takes general price inflation into consideration.

Adjustments are made to the house price and rent growth paths of the

benchmark loss experience equal to the percentage change in the ten-

year

[[Page 18092]]

CMT in excess of 50 percent.\35\ For example, if the ten-year CMT

increases by 60 percent, house price and rent growth rates increase by

ten percent. The stress test phases in this increase in equal monthly

increments during the last five years of the stress period.

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\35\ The stress test computes the difference between the level

of the ten-year CMT in the last nine years of the stress period and

the level of the ten-year CMT if it had increased 50 percent. The

difference in yield is compounded over a nine-year period to

determine the cumulative percentage adjustment to house prices at

the end of the stress period.

---------------------------------------------------------------------------

4. Mortgage Performance

To simulate how mortgages fare during the adverse conditions of the

stress period, the stress test uses models of mortgage performance,

that project default, prepayment and loss severity rates. These models

simulate the interaction of the patterns of house prices, residential

rents, and vacancy rates of the benchmark loss experience, as well as

stress test interest rates, and mortgage risk factors, in order to

determine the performance of Enterprise loans for each month of the

stress test. As described below in further detail, the models are based

on the historical relationship of economic and mortgage risk factors to

mortgage performance, as reflected in the historical experience of the

Enterprises.

a. Loan Groups

Rather than simulating the behavior of individual loans, the models

simulate the behavior of groups of loans with common risk

characteristics. The default and prepayment models calculate the

proportion of the outstanding principal balance for each loan group

that defaults, prepays, or makes regularly scheduled loan payments in

each of the 120 months of the stress period. Single family loans are

aggregated into loan groups based on key risk and cash flow

characteristics: product type \36\ (e.g., 30-year fixed-rate, 15-year

fixed-rate, adjustable rate, balloon), original LTV, interest rate,

origination year, remittance cycle \37\ and Census division.

Multifamily loans are similarly aggregated by product type, original

LTV, origination year, interest rate, and Census region, as well as by

debt coverage ratio (DCR) \38\ and program type. Program type

distinguishes between loans purchased individually rather than as part

of a pool, and loans subject to recourse or repurchase.\39\ These

distinctions are associated with different risk characteristics.

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\36\ The 1992 Act requires that the stress test take into

account appropriate distinctions among mortgage product types,

including single or multifamily, fixed or adjustable interest rates

and the term of the loans.

\37\ For sold loans, the remittance cycle governs the length of

time an Enterprise holds payments remitted by the seller/servicer

before passing them through to the security investor.

\38\ DCR is the ratio of property net income to debt service.

\39\ Recourse refers to the sharing of credit risk with a

seller/servicer; repurchase refers to the obligation of a seller/

servicer to repurchase 90-day delinquent loans.

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b. Single Family Default and Prepayment

The single family models are estimated using historical data on the

performance of Enterprise loans through 1995. To simulate defaults and

prepayments, the stress test uses a 30-year fixed-rate loan model, an

adjustable-rate loan (ARM) model, and a third model for other products,

such as 15-year loans and balloon loans. Each of the three single

family models was separately estimated based on data for the relevant

product types. Each includes a calibration adjustment, so that the

results properly reflect a relationship to the benchmark loss

experience, as described earlier.

All three single family models simulate defaults and prepayments

based on values for interest rates and property values, as described

above, and variables capturing the risk characteristics of loan groups.

The variables described below are the factors used to determine the

rates of default and/or prepayment for single family loan groups:

Mortgage Age--Patterns of mortgage default and prepayment

have characteristic age profiles; defaults and prepayments increase

during the first years following loan origination, and then peak

between the fourth and seventh years.

Probability of Negative Borrower Equity--Borrowers whose

current loan balance is greater than the current value of their

mortgaged property (reflecting negative equity) are more likely to

default than those with positive equity in their properties. The

probability of negative borrower equity within a loan group is a

function of (1) house price changes (based on the HPI), and

amortization of loan principal, which together establish the average

current LTV, and (2) the dispersion of actual house price changes

around the HPI value. Thus, even when the average current LTV for a

loan group is less than one (positive equity), some percentage of the

loans will have LTVs greater than one (negative equity).

Relative Spread--This variable is an important factor in

determining whether a borrower will prepay. It reflects the value to a

borrower of the option to prepay and refinance. The stress test uses

the relative spread between the interest rate on a loan and the current

market rate on loans as a proxy for the mortgage premium value.

Burnout--The value for this variable reflects whether a

borrower has passed up earlier opportunities to refinance at favorable

interest rates. Such a borrower is less likely to prepay the current

loan and refinance, and more likely to default in the future.

Yield Curve Slope--This variable reflects the relationship

between short and long term interest rates. The shape of the yield

curve, which reflects expectations for the future levels of interest

rates, influences a borrower's decision to prepay a mortgage. Depending

on the slope of the yield curve and the type of loan a borrower may

have incentives to refinance to a fixed-rate or an adjustable-rate

mortgage.

Original LTV--The LTV at the time of mortgage origination

serves as a proxy for factors relating to the financial status of a

borrower, which can affect the borrower's future ability to make loan

payments. Higher original LTVs, which generally reflect fewer economic

resources and greater willingness to take financial risk, increase the

probability of default and lower the probability of prepayment. The

reverse is true for lower original LTVs.

Occupancy Status--The value of this variable reflects the

higher probability of default of investor-owners compared to that of

occupant-owners. The stress test applies the portfolio-wide ratio of

investor-to occupant-owners to each loan group. The single family

default and prepayment variables are listed in Table 1.

[[Page 18093]]

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c. Multifamily Default and Prepayment

The stress test utilizes two multifamily default models and five

multifamily prepayment models to capture the behavior of loans

purchased under different programs and loans at different stages in

their life cycles. The models were estimated using historical data

through 1995 on the performance of Enterprise multifamily loans. The

stress test applies one default model to loans purchased under cash

programs (i.e., loans purchased individually), and another to loans

purchased under negotiated programs (i.e., loans purchased as part of a

pool), because the programs have different risk profiles. The

prepayment models distinguish among product types: fully-amortizing

fixed-rate, balloon, and ARM loans; those with yield maintenance

provisions (i.e., restrictions and/or penalties for prepaying a loan

during a specified period of time); and balloon loans which have

reached their stated maturity, because these distinctions affect the

probability of prepayment.

As with the models of single family mortgage performance, the

multifamily models simulate the probability of default and prepayment

based on stress test conditions and loan group risk characteristics. To

account for specific risks associated with multifamily loans, these

loans are grouped somewhat differently from single family loans. Thus,

multifamily loans are also grouped by original DCR and program type.

All of the multifamily default and prepayment models include interest

rates, rent growth rates, and vacancy rates to characterize stress test

conditions.

The following variables are factors in determining default and

prepayment rates for multifamily loan groups:

Mortgage Age--As with single family loans, the risk of

default and prepayment on multifamily loans varies over their lives.

Relative Spread--As with single family loans, this

variable reflects the value to the borrower of the option to prepay and

refinance.

Program Restructuring--This variable captures the

difference between Enterprises' management of their original

multifamily programs and current, restructured programs. That

difference affects the probability of default.

Joint Probability of Negative Equity and Negative Cash

Flow--This variable plays a role similar to that of the probability of

negative equity for single family loans. However, negative equity is

not a sufficient condition for multifamily loan default. Residential

rental property owners tend not to default unless a property's net cash

flow is negative as well. This variable captures the joint probability

of both conditions.

Balloon Maturity Risk--To reflect the added risk of

default at the balloon maturity date, this variable gives extra weight

to the joint probability of negative equity and negative cash flow in

the year before a balloon mortgage matures.

Default Type--This variable distinguishes between loans

for which the Enterprise is responsible for foreclosure and property

disposition and loans for which the seller/servicer is responsible for

repurchasing if the loan becomes 90 days delinquent.

Current LTV--This variable captures the incentive for

borrowers to refinance in order to withdraw equity from their rental

property.

Probability of Qualifying for Refinance--This variable

captures the effect on prepayments of a borrower who would not qualify

for a new loan (one that lacks an LTV of 80 percent or less and a DCR

of 120 percent or more).

Pre-balloon Refinance Incentive--This variable gives extra

weight to the relative spread in the two years prior to the balloon

maturity. This captures the additional incentive to prepay balloon

loans after the date the yield maintenance period ends, but before the

balloon maturity date.

Conventional Market Rate for Mortgages--Similar to the

single family yield curve slope variable, this variable reflects the

incentives for borrowers with ARMs to refinance into fixed-rate

mortgages.

Value of Depreciation Write-offs--This variable captures

the effect on default rates of the value to a new purchaser of the tax

benefits associated with multifamily property ownership.

Years-To-Go in the Yield Maintenance Period--This variable

captures the decreasing effect of yield maintenance provisions during

the yield maintenance period. As the cost of the provision declines in

the later years of the yield maintenance period, the disincentive to

prepay declines.

Just like the single family default and prepayment models, the

multifamily models produce, for each loan group for each month of the

stress period, default and prepayment rates which are used in the cash

flow components of the stress test. Tables 2 and 3 list the variables

included in the multifamily default and prepayment models.

[[Page 18094]]

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[GRAPHIC] [TIFF OMITTED] TP13AP99.188

d. Loss Severity

Credit losses are determined by multiplying default rates by loss

severity rates and loan group balances. Loss severity rates are

computed as of the date of default, and are expressed as a percentage

of unpaid principal balance of the defaulting portion of a loan group.

In general, losses comprise three elements--loss of principal,

transactions costs, and funding costs. Loss of principal is the amount

of defaulting loan UPB, offset by the net proceeds of the sale

(disposition) of the foreclosed property. Transactions costs include

[[Page 18095]]

expenses related to foreclosure, property holding and disposition

expenses. Funding costs are the costs of funding non-earning assets--

first the defaulted loans, and then the foreclosed properties prior to

disposition (except in the case of sold loans, for which four months of

interest at the passthrough rate replace four months of funding costs).

For single family loans the stress test uses an econometric model

to project the net proceeds from the sale of foreclosed properties. The

model is based on historical data on defaulted Enterprise loans, and

reflects the relationship between LTV at the time of loan default

(based on a loan's original LTV, loan amortization, and house price

changes and dispersion), and proceeds of property disposition. Just as

with models of single family default and prepayment, this model

includes a calibration adjustment to make the results consistent with

the benchmark loss experience.

For multifamily loans, sale proceeds are a fixed percentage of the

defaulting UPB, based on historical experience.

For both single family and multifamily loans, transactions costs

are fixed amounts based on historical averages computed from Enterprise

data. Funding costs are captured in a discounting process described in

the following paragraph.

Foreclosure, disposition and associated costs occur over a period

of time. In order to calculate losses associated with a default as of

the time of the default, the stress test calculates loss severity rates

by discounting the different elements of loss back to the time of

default, based on stress period interest rates. The discounting process

also captures funding costs at appropriate interest rates. For single

family loans, the timing of each element is based on averages for the

benchmark loans; for multifamily loans it is based on the historical

average for the Enterprises, using data through 1995.

The calculation of loss severity rates for two types of multifamily

loans differs from the general approach. In the case of 90-day

delinquent loans that are repurchased from Enterprise security pools by

seller/servicers, rates are a fixed amount based on Enterprise

historical experience representing claims submitted by seller/servicers

for reimbursement by the Enterprise. In the case of FHA-insured loans,

the stress test reflects no losses.

The loss severity component of the stress test generates loss

severity rates for each loan group for each month of the stress period,

which are used in the cash flow components of the stress test to

calculate credit losses for the Enterprises.

5. Other Credit Factors

a. Mortgage Credit Enhancements

In many cases, at least a portion of Enterprise losses on defaulted

loans is offset by some form of credit enhancement. Credit enhancements

are contractual arrangements with third parties that reduce Enterprise

losses on defaulted loans. By including the effect of mortgage credit

enhancements, the stress test more realistically reflects Enterprise

risks related to mortgage defaults and credit losses during the stress

period.

The stress test captures many types of credit enhancements, with

differing depths and methods of coverage, for both single family and

multifamily loans. These credit enhancements include private mortgage

insurance, recourse to seller/servicers, indemnification, pool

insurance, cash accounts, spread accounts, collateral accounts, and

specific risk-sharing agreements for certain multifamily loans.

The stress test divides mortgage credit enhancements into two

categories. One category is credit enhancements that cover losses on

certain loans up to a specified percentage of the loss incurred. This

category includes private mortgage insurance, unlimited recourse,

unlimited indemnification and, for certain multifamily loans, risk-

sharing agreements. The other category includes those credit

enhancements that cover all losses on a specified set of loans, up to a

specified total amount. This category includes limited recourse,

limited indemnification, pool insurance, cash accounts, spread accounts

and collateral accounts.

The benefits of the first category of credit enhancements are

incorporated in the calculation of monthly loss severity rates. The

loss severity rate for a specific loan group is reduced based on the

credit enhancements from the first category associated with loans in

that group. The benefits of the second category of credit enhancements

are taken into account directly in the cash flow calculations. The

dollar balance of these credit enhancements is tracked and drawn down

to offset the amount of credit losses for the covered loans in a loan

group.

b. Counterparty and Other Credit Risk

In addition to mortgage credit quality, the stress test considers

the creditworthiness of companies and financial instruments to which

the Enterprises are exposed. These include most mortgage credit

enhancement counterparties (e.g., private mortgage insurance companies

and seller/servicers), privately issued and municipal securities held

as assets, derivative counterparties, and securities guaranteed for

private issuers.

For credit enhancement counterparties, securities held as assets,

and interest rate contract counterparties, the stress test reduces--or

applies ``haircuts'' to--the amounts due from these instruments or

counterparties according to their level of risk. The level of risk is

determined by public credit ratings which the stress test classifies

into four categories: AAA, AA, A and BBB. When no rating is available,

the instrument or counterparty is rated BBB. The cash flow components

of the stress test phase in the haircuts monthly in equal increments

until the total reduction listed in Table 4 is reached in the final

month of the stress period.

[[Page 18096]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.189

The stress test also applies haircuts to reflect the impact of

impairment of counterparties for derivative contracts hedging foreign

currency denominated debt. Since counterparty impairment would reduce

the effectiveness of a hedge, the stress test reflects the associated

risk by increasing the amounts owed by an Enterprise by the haircut

percentage.

c. Other Off-Balance Sheet Guarantees

In addition to guaranteeing mortgage-backed securities they issue

as part of their main business, the Enterprises occasionally provide

guarantees for other securities. The guarantees provided by the

Enterprises enhance the liquidity and appeal of these securities in the

marketplace. These securities, notably single family and multifamily

whole loan REMIC securities \40\ and mortgage tax-exempt multifamily

housing bonds, represent a small part of the Enterprises' business and

have a significant level of credit enhancement that protects the

Enterprises from losses. The performance of these securities is not

explicitly modeled in the stress test. As a proxy for the present value

of net losses on these guarantees during the stress test, the

outstanding balance of these instruments at the beginning of the stress

period is multiplied by 45 basis points. The resulting amount is

subtracted from the lowest discounted monthly capital balance when

calculating the risk-based capital requirement.

---------------------------------------------------------------------------

\40\ Real Estate Mortgage Investment Conduit (REMIC) securities

are multiclass mortgage passthrough securities. The classes of a

REMIC security can take on a wide variety of attributes with regard

to payment of principal and interest, cash flow timing

(un)certainty, and maturity, among others.

---------------------------------------------------------------------------

6. Cash Flows

For each month of the stress period, stress test cash flow

components apply projected default, prepayment, and loss severity rates

to loan group balances to produce mortgage cash flows. The cash flow

components also reduce projected mortgage losses resulting from

offsetting credit enhancements that are not accounted for in loss

severity calculations. In addition, the cash flow components calculate

cash flows for securities that the Enterprises hold as assets, or have

issued as liabilities. They generate cash flows for derivative

instruments like interest rate swaps, caps, and floors; and they apply

the haircuts to cash flows to reflect the credit risk of securities and

counterparties other than mortgage borrowers. Projected cash flows are

the principal inputs in the creation of monthly financial statements

during the stress period, which are, in turn, the basis for the

calculation of the risk-based capital requirement.

Cash flows are generated for each single family and multifamily

loan group. For retained loans, cash flows consist of scheduled

principal, prepaid principal, defaulted principal, default losses, and

interest. For sold loans, cash flows consist of credit losses,

guarantee fee income, and float income.

Because losses on sold loans are absorbed by the Enterprises and

are not passed through to security holders, no credit losses are

reflected in cash flows calculated for Enterprise-issued MBS held as

investments (including those issued by an Enterprise and later

repurchased). The credit risk is borne by the MBS issuer rather than

the MBS investor, so the credit risk on MBS has already been taken into

account in the credit risk of sold loans. Thus, cash flows for single

class Enterprise-issued MBS held as investments consist only of

principal and interest payments. Cashflows for private label securities

consist of principal and interest payments and credit losses.\41\

Principal payments are calculated by applying default and prepayment

rates that are appropriate for the loans underlying the MBS (amounts of

defaulted principal are assumed to be passed through to investors, as

well as normal amortization). Interest is computed by multiplying the

security principal balance by the coupon rate.

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\41\ See section II. A. 5. c., Other Off-Balance Sheet

Guarantees for a description of how credit losses for private label

securities are calculated.

---------------------------------------------------------------------------

Multi-class mortgage securities such as REMICs and strips are

treated in the same manner as single class MBS. The stress test

generates cash flows for the underlying collateral, usually single

class MBS, and applies the rules of the particular multi-class security

that govern how these cash flows are directed to determine cash flows

of the specific securities held by an Enterprise. In generating cash

flows for mortgage-linked derivative contracts, where the notional

amount of the contract is based on the declining principal balance of

specified MBS, the stress test applies the terms of each contract and

tracks the appropriate declining balances. The stress test generates

cash flows for mortgage revenue bonds by treating the bonds like single

class MBS backed by 30-year, fixed-rate single family mortgages

maturing on each bond's stated maturity date.

For non-mortgage investments, outstanding debt securities and

liability-linked derivative contracts, payments of principal and

interest are calculated for each instrument based on its

[[Page 18097]]

characteristics by applying the appropriate interest rates and

principal payment rules. For asset-backed securities, one of two

collateral prepayment speeds is applied, depending on the stress test

interest rate scenario. The stress test computes cash flows for debt

securities and liability-linked derivatives according to the rules and

structure of each instrument.

7. Enterprise Operations & Taxes

The stress test simulates the income taxes, operating expenses,

issuance of new debt or purchase of new investments, exercise of

options to retire debt early or cancel derivative contracts, and

payment of dividends by the Enterprises. The stress test computes

Federal income taxes using an effective tax rate of 30 percent.

Estimated income tax is paid by the Enterprises quarterly.

An Enterprise's operating expenses decline in proportion to the

change in the size of its combined mortgage portfolio of retained and

sold loans during the stress period. The baseline level of monthly

operating expenses at the start of the stress period is equal to one-

third of operating expenses reported by the Enterprise for the quarter

preceding the stress period.

When necessary, the stress test simulates the issuance of new debt

or purchase of new investments by the Enterprises. New debt is issued

in months when there is a shortfall of cash. All debt issued during the

stress period is six-month discount notes, at Enterprise borrowing

rates projected from the estimated yield curve. Excess cash is invested

in one-month securities bearing the six-month Treasury yield.

For each month during the stress period that a security is subject

to early redemption (call) or a derivative contract is subject to

cancellation, the stress test calculates the effective remaining yield-

to-maturity \42\ of that instrument and compares it to the yield of a

replacement security, given current stress period interest rates. If

the yield is more than 50 basis points below the cost of the existing

instrument, the call or cancellation option is exercised.

---------------------------------------------------------------------------

\42\ Yields are calculated based on the outstanding principal

balances for securities and notional amounts for derivative

contracts.

---------------------------------------------------------------------------

Capital distributions are also made during the stress period. If an

Enterprise's capital exceeds the minimum capital requirement in any

quarter, dividends on preferred stock are paid, unless payment would

reduce the Enterprise's capital to an amount below the minimum

requirement. Common stock dividends are paid only in the first four

quarters of the stress period (based on an estimate of how long capital

would remain above the risk-based requirement), and only if capital

remains above the minimum capital requirement before and after the

dividends are paid. The amount paid is directly related to the earnings

trend of the Enterprise. If the trend is positive, the dividend payout

ratio is the same as the average of the four quarters preceding the

stress test. Otherwise, dividends are based on the dollar amount per

share paid in the last quarter preceding the stress test. The stress

test does not provide for any other capital distributions, such as

repurchases of common stock.

8. Financial Reporting

To the extent applicable, the stress test makes use of Generally

Accepted Accounting Principles (GAAP). The cash flows from the

financial instruments on the books of the Enterprises are the principal

basis for the creation of pro forma financial statements that capture

an Enterprise's performance over the stress period. In addition, the

stress test accounts for numerous non-cash items on the Enterprises'

balance sheets, such as receivables and unamortized and deferred

balances. The balance sheets show the monthly total capital amount for

each Enterprise, which is used in the final calculation of risk-based

capital.

9. Calculation of the Risk-based Capital Requirement

The stress test determines the amount of capital that an Enterprise

must hold at the start date in order to maintain positive capital

throughout the ten-year stress period (stress test capital). Once

stress test capital has been calculated, an additional 30 percent of

that amount is added to protect against management and operations risk.

This total is the risk-based capital requirement.

Using the financial statements generated by the stress test, the

capital balance for each month is discounted back to the start of the

stress period. This is done for both the up-rate and down-rate

scenarios. The lowest discounted monthly capital balance is then

decreased as described above to account for securities that are

guaranteed by the Enterprises which are not explicitly modeled (other

off-balance sheet guarantees). This lowest discounted monthly balance,

if positive, represents a surplus of initial capital, that is, capital

that was not ``used'' during the stress period. If negative, it

represents a deficit of initial capital. The lowest discounted monthly

balance is then subtracted from the Enterprise's initial capital. The

resulting amount is the smallest amount of starting capital required to

maintain positive capital throughout the stress period.

For example, if an Enterprise holds starting capital of $10 billion

and the lowest discounted monthly balance is $1 billion (representing a

positive capital balance even in the worst month of the stress period),

then the amount of starting capital necessary to maintain positive

capital throughout the stress period is $9.0 billion. If the lowest

discounted monthly balance is -$1 billion (representing a negative

capital balance in the worst month), the necessary starting capital is

$11.0 billion.

In the final step, necessary starting capital is multiplied by 1.3

to complete the calculation of the risk-based capital requirement

required by the 1992 Act.

B. Sensitivity of Capital Requirement to Risk

An Enterprise's risk-based capital requirement under this proposed

regulation is sensitive to a wide variety of factors that affect

Enterprise risk. The existing minimum capital requirement depends

almost entirely on the size of an Enterprise's two principal

businesses: MBS guarantees and leveraged investments in mortgages and

in MBS. In contrast, the risk-based capital requirement depends not

only on the outstanding volumes of an Enterprise's guarantees and

assets, but also on the degree of risk taken on by the Enterprise in

connection with these businesses. Thus, the risk-based requirement is

sensitive to the characteristics of mortgages and mortgage guarantees

that affect risk, credit enhancements for those mortgages, the asset/

liability risk management strategies of the Enterprise, the value of

properties collateralizing the mortgages, and recent interest rate

levels.

In designing the stress test on which the risk-based capital

requirement is based, OFHEO sought to incorporate all significant

sources of credit and interest rate risk. OFHEO further sought to

design the stress test so that differences in specific risk factors

affect the risk-based capital requirement in amounts commensurate with

the difference in risk. To quantify the marginal effects of changes in

risk on the capital required for each scenario (required capital),

OFHEO conducted a number of sensitivity tests. OFHEO first computed the

risk-based capital requirement for each Enterprise in each interest

rate

[[Page 18098]]

scenario for June 30, 1997.\43\ These results serve as a base case.

OFHEO then made a series of small adjustments to each Enterprise's risk

positions and compared the results for all four Enterprise-scenario

combinations with the relevant base case results. The differences in

results provide a measure of the incremental changes in required

capital (which may be positive or negative) caused by the risk

adjustment.

---------------------------------------------------------------------------

\43\ The results are discussed in section II. C., Implications

of the Proposed Rule.

---------------------------------------------------------------------------

Section II. B.1., MBS Guarantees (Sold Loans), below presents the

results of sensitivity tests related to an Enterprise's guarantee

business. In each test, OFHEO simulated the effects on required capital

of a hypothetical addition to each Enterprise's outstanding MBS

guarantees (sold loans). The simulation results show, in both an

absolute and relative sense, how different characteristics of sold

loans affect required capital. Section II. B. 2., Commitments,

illustrates how required capital would be affected if each Enterprise

had had a larger volume of outstanding commitments. Section II. B. 3.,

Assets and Liabilities, discusses the effects of hypothetical additions

of retained loans accompanied by additions of debt. Section II. B. 4.,

Administrative Costs, discusses how risk-based capital would be

affected by higher administrative (operating) expenses. Finally,

Section II. B. 5., External Economic Conditions, discusses how risk-

based capital would be affected had house prices or interest rates

behaved differently than they actually did in the period just preceding

the starting date of the stress test.

Sensitivity test results differ between the two Enterprises for two

reasons. First, the risk adjustments made to the two Enterprises'

positions were not precisely the same. For example, in sensitivity

tests involving changes in outstanding sold loan volumes, each

Enterprise's additional sold loans reflect that Enterprise's typical

security remittance cycles, and remittance cycles affect the risk

characteristics of sold loans. Second, the incremental effects on

required capital of any change in an Enterprises's risk positions are

affected by the Enterprise's individual circumstances and policies. Two

examples are the Enterprise's projected Federal income tax situation

during the stress period and its dividend policies. During portions of

the stress period in which an Enterprise is paying taxes or receiving

refunds, financial gains and losses are shared with the government

because changes in income cause changes in taxes. Conversely, during

portions of the stress period in which an Enterprise has exhausted tax

carrybacks, the full benefit or cost of a change in income is

experienced by the Enterprise. In the base case, both Enterprises

exhaust their tax carrybacks mid-way through the stress period in the

down-rate scenario. In the up-rate scenarios, Fannie Mae does the same,

but Freddie Mac either pays taxes or receives refunds throughout the

stress period. An Enterprise's tax situation during the stress period

depends primarily on the Enterprise's risk exposures. The longer an

Enterprise continues to be profitable in the stress environment, the

longer it is affected by taxes.

Differences in recent dividend policies can cause small differences

in the incremental capital associated with specific changes in risk

because common stock dividends during the first year of the stress

period depend on recent dividend payouts. Differences in dividend

policies, therefore, can lead to differences in the amount of earnings

changes that are shared with stockholders.

Results are shown for both interest rate scenarios, even though

only one (the one that results in the highest required capital) can be

binding at any specific time. For June 1997, the up-rate scenario

resulted in higher required capital for Fannie Mae, while the down-rate

scenario was more adverse for Freddie Mac. However, the relative

adversity of the two scenarios may change over time for either

Enterprise depending on business strategies and market conditions.

In the tables of this section, the phrase ``incremental capital''

is used to mean the change in the amount of required capital in a

particular scenario accompanying a small change in the overall risk

profile of an Enterprise. Several considerations affect appropriate

interpretation of these numbers. First, the incremental capital

percentages shown in the tables are not fixed. As discussed below in

section II. B. 5. c., Sensitivity to Risk Characteristics in Different

Economic Environments, future business strategies and economic

conditions may alter the required capital sensitivities from those of

June 1997, which are presented here. Furthermore, bigger or smaller

changes in risk may not have a proportional effect on capital. A $20

billion increase in a particular group of loan guarantees may not have

exactly twice the effect on required capital as a $10 billion increase

in the same group of guarantees.

Second, in anticipating the effect on required capital of a change

in any risk factor, an Enterprise likely will be concerned not only

with the immediate effect, but also with the longer term effect. For

example, in considering the capital implications of making additional

mortgage guarantees, the incremental effects on required capital of the

guarantees at all future dates that the loans continue to be

outstanding are relevant. In this case, an important consideration is

that the incremental effects of mortgage guarantees generally diminish

over time.

Third, the incremental capital percentages do not determine an

amount of capital that must be added in order to accept a specific

increase in risk. As discussed below in Section II. C. 2., Enterprise

Adjustments to Meet the Proposed Standard, it may often be less costly

to increase hedges of other risks than to raise equity funds in

response to an increase in risks.

1. MBS Guarantees (Sold Loans)

The Enterprises have two principal lines of business. They function

both as guarantors of mortgage-backed securities and as leveraged

investors in mortgages and mortgage-backed securities. As guarantors,

the Enterprises receive principal and interest payments on home

mortgages, which they pass through to security investors, minus a share

of the interest payments, which they retain as a guarantee fee. Because

of differences in the timing of their receipt of funds and payments to

investors, they also earn float income (which may be positive or

negative). In return, they bear the risk of loss if a borrower

defaults, and they incur additional administrative expenses.

The stress test projects the flows of income and expenses

associated with loan guarantees based on the characteristics of the

mortgages and the economic circumstances of the stress period. The

resulting net cash inflows or outflows are directly reflected in the

Enterprise's borrowing or investing volumes during the stress period.

The interest paid or received on the new debt issues or investments

that are attributable to the guarantees have further effects on income,

borrowing, and investing volumes. Income, in turn, affects taxes,

dividends, capital, and (ultimately) required capital.

OFHEO examined the implications for required capital of risk

factors associated with sold loans as follows. After computing the

capital required under this proposed rule for data reflecting the

Enterprises' books of business and the accompanying economic

circumstances as of June 30, 1997, OFHEO added a quantity ($10 billion)

of sold loans that embodied the specific risk characteristics under

[[Page 18099]]

examination. The capital required for each scenario was then recomputed

and compared with the capital required for the same scenario before

loans were added. The difference is the incremental capital required

for the additional sold loans in that scenario. The results are

expressed as a percent of the volume of sold loans added.

Additional sold loans would normally be accompanied by additional

administrative expenses. In computing required capital for books-of-

business that included additional sold loans, OFHEO estimated the

additional costs by increasing administrative expense for each

Enterprise in proportion to the increase in that Enterprise's overall

(retained plus sold loan) portfolio. Those costs amounted to about six

basis points (0.06 percent) per year on the new sold loans for each

Enterprise. Different assumptions about administrative costs would

affect the results; Section II. B. 4., Administrative Costs, discusses

the effects on required capital of differences in administrative costs.

Section II. B. 1. a., Loans with Mixed Characteristics Reflecting

Enterprise Portfolios, discusses a simulation incorporating a general

increase in sold loans embodying the same mix of characteristics as

that found in each Enterprise's sold loan portfolio in June 1997 and

describes how the increase affects various types of income and expense

over the course of the stress period. Section II. B. 1. b., Loans with

Specific Identical Characteristics, discusses a series of simulations,

each incorporating an increase in sold loans with specific

characteristics.

a. Loans with Mixed Characteristics Reflecting Enterprise Portfolios

The first simulation (Simulation 1) was designed to examine the

incremental effects of a general increase in each Enterprise's sold

loan portfolio (MBS guarantees). The volume of each loan group

(comprising loans with a common set of risk factors) in each

Enterprise's sold loan portfolio as of June 1997 was increased

proportionally by a factor that resulted in a total of $10 billion of

additional sold loans. The results indicate the effects on risk-based

capital of a general expansion of an Enterprise's MBS guarantee

business. Alternatively, they can be viewed as the average effect on

required capital of sold loans, weighted by each Enterprise's mix of

outstanding sold loan business in June 1997. The results, expressed as

a percent of the increase in sold loans, are summarized in Table 5.

[GRAPHIC] [TIFF OMITTED] TP13AP99.190

In the up-rate scenario, a general increase in sold loans has only

a small effect on required capital for either Enterprise. For Freddie

Mac, sold loans are, on balance, a small source of strength. That is,

income generated over the course of the stress period by sold loans

(principally guarantee fees and float) exceeds related expenses

(principally loan losses and administrative expense). The reverse is

true for Fannie Mae. In the down-rate scenario, the incremental capital

required for these sold loan mixes is near 0.85 percent of the increase

in guarantees for both Enterprises. On average, the results for the two

scenarios are similar to the existing minimum capital ratios for sold

loans of 0.45 percent.

Table 6 illustrates the effects on specific income and expense

categories of the additional sold loans in Simulation 1, and how these

effects translate into changes in capital requirements.

[[Page 18100]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.191

Guarantee fees and administrative expense depend on the volume of

loans outstanding. Thus, they are sensitive to the projected

liquidation rates (the sum of prepayment, default, and amortization

rates) of the additional sold loans. In the down-rate scenario (with a

ten-year constant maturity treasury yield of 3.2 percent during the

last nine years of the stress period), loans prepay rapidly, while in

the up-rate scenario (with all treasury yields at 11.4 percent), loans

prepay slowly. As a result, in the up-rate scenario, guarantee fee

income and administrative expense are roughly 2\2/3\ times as great as

they are in the down-rate scenario.

Credit losses (charge-offs) depend on the credit risk

characteristics of the additional sold loans. They are also larger in

the up-rate scenario than in the down-rate scenario because loans

remain outstanding longer, and therefore, at risk of default. Loss

severity rates also are higher in the up-rate scenario because the

interest carrying cost on foreclosed real estate is higher. These

differences between the two scenarios are moderated by somewhat more

favorable house price behavior and by better average loan quality when

interest rates are high. Loan quality is poorer when interest rates are

low because the better quality loans are projected to prepay much

faster. Because of these offsetting influences, credit losses in the

up-rate scenario are only 1\1/3\ times as great as they are in the

down-rate scenario. Freddie Mac's credit losses are about ten percent

lower than Fannie Mae's, reflecting a slightly less risky mix of loan

characteristics.

Float income depends on security remittance cycles, interest rates,

and loan liquidation rates. This source of income on the additional

sold loans is higher, for both Enterprises, in the scenario with higher

interest rates because of lower liquidation rates and higher earnings

ratios on positive float balances. The difference is much more

pronounced for Freddie Mac because of differences in security

remittance cycles. Freddie Mac holds prepayment funds for a longer

period than Fannie Mae, earning a market rate of interest during the

extra time, while accruing liabilities to investors at the security

coupon rate. When interest rates rise, that provides extra income, but

when rates fall, net losses accrue.

Net interest income is affected because net cash inflows and

outflows associated with the other income and expense categories lead

to changes in borrowing or investing. The effects are small in the up-

rate scenario because the net flows caused by other factors are small.

The effects also are small in the down-rate scenario, even though the

net cash flows are much larger, because the interest rates associated

with new borrowing or investing are low.

Taxes reduce the effects of all income changes by 30 percent as

long as an Enterprise is paying taxes or receiving tax refunds. Because

both Enterprises, in the decreasing interest rate environment, and

Fannie Mae, in the increasing rate environment, exhaust their tax

carrybacks mid-way through the stress period, the tax effects vary

depending on the timing of income flows during the stress period.

Freddie Mac, however, performs well in the up-rate scenario, given its

June 1997 risk positions, and pays taxes or receives refunds throughout

the stress period.

[[Page 18101]]

Dividends on common stock can be affected by additional sold loans

only through changes in income during the first year of the stress

period because the stress test specifies that common stock dividends

are paid only during that year. Common stock dividends are little

affected in this simulation because income changes during the first

year are small and because dividends in the base case simulations for

Fannie Mae in both scenarios, and Freddie Mac in the down-rate

scenario, are insensitive to income. In those cases, dividends are set

at their absolute level in the quarter preceding the stress test

because of income declines during the first year. Preferred stock

dividends are unaffected in this simulation because the changes in

capital are insufficient to affect whether either Enterprise meets its

minimum capital requirement during the stress period.

The total change in capital is the sum (using the appropriate

signs) of the effects measured through all of the above income and

expense categories. The sum equals the net decline in capital at the

end of the stress period (as a percent of the increase in sold loans).

The capital position in the final month of the stress period is the

lowest during the stress period for both Enterprises in both scenarios

for the June 1997 base case, so it is the basis for the required

capital calculations in all of the simulations discussed in this

section.

The cumulative discount factor is based on after-tax borrowing or

investing interest rates. Thus, discount factors are relatively high in

the up-rate scenario. Freddie Mac's discount factor is lower than

Fannie Mae's in that scenario because taxes reduce Freddie Mac's after-

tax interest rates in the second half of the stress period, but do not

reduce Fannie Mae's. The discounted total shows the effects of the

additional sold loans on the amount of capital needed to survive the

stress test. This amount, when multiplied by 1.3 to include the

additional amount for management and operations risks, shows the

effects on required capital of the additional sold loans.

b. Loans with Specific Identical Characteristics

Unlike the first simulation, which showed the combined effects of

each Enterprise's existing mix of risk factors, the following

simulations focus on the effects of changes in specific risk factors.

In each of the following cases, the sold portfolio is increased as

before, but all of the additional loans are identical. The results show

how much required capital would be affected by additional sold loans

with specific risk characteristics and guarantee fees or,

alternatively, how much loans with such characteristics and fees

contribute to required capital. The assumptions about guarantee fees

have a significant effect on the results. Guarantee fees are generally

the same in most of these simulations in order to focus the results on

the incremental capital effects of specific risk factors. In practice,

though, the Enterprises typically vary the guarantee fees charged to a

loan seller depending on the mix of loans they receive from that

seller. Thus, the Enterprises implicitly charge higher fees for riskier

loans. It would be misleading to characterize these simulation results,

which are based on constant guarantee fees, as indicating the relative

capital implications of loans in different risk groups as typically

acquired by the Enterprises, without making an appropriate adjustment

for typical differences in effective guarantee fees. Making such an

adjustment in the model would be difficult, however, because the

Enterprises do not generally make explicit differences in guarantee

fees for individual loans with differences in risk. The same guarantee

fee typically applies to all loans in a pool of loans and may be

affected by the mix of loans in the pool.

Also, Enterprise guarantee fees remain constant over the life of

the loan, but the risk of the loan generally declines as the loan

seasons. A majority of the simulations in this subsection involve new

loans. The comparative results of such simulations provide a measure of

the relative effects on required capital of different risk factors, but

these results do not, by themselves, indicate the expected effects on

required capital of the loans over their lifetimes. Additional

simulations show the effects of loan seasoning on required capital.

In these simulations, securities were assumed to have been sold at

par with coupons equal to the contract interest rates, less the

servicing and guarantee margins. Servicing margins are 30 basis points.

For Fannie Mae, the loans were assumed to be securitized under their

standard programs with seven days of float on passthrough payments. For

Freddie Mac, their ``45-day'' security rules were assumed in float

calculations. These securities have negative three days of float on

scheduled principal and interest (payments are made to investors before

payments are received from servicers) and an average of 38 days of

float on prepayments. (In Simulation 1, both 45-day and 75-day rules

were used for Freddie Mac, based on the mix of securities outstanding

in June 1997.)

(i) Differences in Guarantee Fees

To illustrate the effect on required capital of guarantee fees, two

simulations were performed that were identical except for guarantee

fees. In Simulations 2 and 3, shown in Table 7, the additional sold

loans were all newly originated, fixed-rate mortgages (FRMs) in the

West South Central Census Division (Texas, Oklahoma, Louisiana, and

Arkansas); with 30-year terms, 7.5 percent contract interest rates, and

80 percent loan-to-value ratios (LTVs). In Simulation 2, guarantee fees

were set at 23 basis points, which is roughly the overall average rate

for the two Enterprises, but not necessarily for loans with these

characteristics. This simulation is used as a reference for comparison

in Tables 8, 11, 12, 16, 17, 19, and 20. The average rate was used in

most of the simulations involving additional single family loans for

convenience and to isolate the differential effects of other risk

factors. In Simulation 3, however, the guarantee fee was reduced to 18

basis points to isolate the effects of different guarantee fees. The

differences in the results for Simulations 2 and 3 can be used to

roughly estimate how the results of other simulations might have been

affected by other guarantee fee assumptions.

[[Page 18102]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.192

The incremental capital needed for loans in both of these

simulations is substantially higher than that needed for loans with the

mix of characteristics in Simulation 1. This result occurs mainly

because new 30-year FRMs have nearly double the credit losses in the

up-rate scenario and 50 percent more in the down-rate scenario. For

Freddie Mac, an additional reason is that securities with the 45-day

remittance cycle assumed in Simulations 2 and 3 produce substantially

less float income in the up-rate scenario and more negative float

income in the down-rate scenario than the average guarantee mix in

Simulation 1 did. Freddie Mac's capital need in the up-rate scenario is

reduced relative to Fannie Mae's because of tax effects in the second

half of the stress period.

The effect of lower guarantee fees is to increase required capital

in both scenarios. A five basis-point reduction in guarantee fees

raises required capital by 14 to 18 basis points in the down-rate

scenario. The difference in incremental capital is twice that amount in

the up-rate scenario because the loans survive longer, owing to

significantly fewer prepayments, and so the change in the fee rate

applies to a larger volume of outstanding loans during the stress

period.

(ii) Differences in Loan Age, With Slow and Steady House Price

Inflation

Seasoned loans (those not recently originated) have different risk

characteristics than new loans because loans have different

propensities to default and prepay at different ages and because the

houses collateralizing seasoned loans have experienced changes in

value. Changes in house value alter the probability of negative

borrower equity, a key factor influencing default behavior.

In Table 8, the results of Simulations 4-7, along with Simulation

2, which is repeated here, show the effects of age on risk for loans

originated in the West South Central Census Division. Houses in that

area of the country generally have experienced price appreciation near

the national average in recent years. Average annual appreciation over

the eight years ending in the second quarter of 1997 was 3.0 percent.

Table 9 shows the cumulative average appreciation for houses

collateralizing loans of different ages.

[GRAPHIC] [TIFF OMITTED] TP13AP99.193

All of the simulations reported in Table 8 are identical, except

for the age of the sold loans underlying the additional guarantees.

Given the steady increase in house prices preceding the starting point

of the simulations, loans are less likely to default over the course of

the stress period the older they are at the beginning of the period.

Cumulative credit losses for loans made eight years before the start of

the stress period are only about \1/5\ as great as for new loans in the

up-rate scenario, and about \2/5\ as great in the down-rate scenario.

In addition, loans made more than four years earlier have lower

liquidation rates than new loans, providing a larger stream of

guarantee fees. Consequently, guarantees of older loans cause much

smaller increases in capital requirements in the down-rate scenario and

actually reduce capital required in the up-rate scenario.

[[Page 18103]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.194

(iii) Differences in Past House Price Appreciation

The benefits of loan age in reducing risk can be substantially

increased or reversed by differences in house price appreciation. Table

10 shows results for simulations on four-and eight-year-old loans from

different geographic areas. Simulations 8 and 9 are the same as

Simulation 5, except the loans in Simulation 8 were made on properties

in the Mountain Census Division, where house values rose sharply after

the loans were originated, and loans in Simulation 9 were made in the

Pacific Census Division, where house values were stagnant. Similarly,

Simulations 10 and 11 are the same as Simulation 7, except for the

Census division.

[GRAPHIC] [TIFF OMITTED] TP13AP99.195

For four-year-old loans, differences in credit losses are

substantial and account for almost all differences in results. In both

scenarios, credit losses are more than 2\1/2\ times as great in the

Pacific Census Division as they are in the Mountain Census Division.

However, the effects of different previous changes in house prices

ultimately diminish. For eight-year old loans, charge-offs are only

about \1/3\ higher in the Pacific Census Division, despite increasing

disparity in house price appreciation. Furthermore, that smaller

proportional increase in charge-offs is applied to a smaller base

because charge-offs are much lower for eight-year old loans than for

four-year old loans in all three Census divisions.

(iv) Differences in Loan Age and Loan-to-Value Ratio

The higher the original loan-to-value ratio of a loan, the lower

the borrower equity. Thus, the more likely it is to default and less

likely it is to prepay. The effects of differences in original LTV,

however, generally diminish with age. Table 11 shows the results for

different LTV-age combinations for 30-year FRMs in the West South

Central Division.

[[Page 18104]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.196

In these simulations, the 95 percent LTV loans are assumed to be

covered by private mortgage insurance with 30 percent coverage, the

current Enterprise standard, provided by a double-A rated firm. Even

with the insurance coverage, however, high LTV loans are much riskier

than low LTV loans. Not only are high LTV loans more likely to default

at any time during the stress period, but they are also less likely to

prepay, especially in the down-rate scenario. Thus, they are exposed to

default risk over a longer amount of time.

For newly originated loans, the results are particularly striking.

In the up-rate scenario, credit losses on 95 percent LTV loans are very

much higher than they are for 50 percent LTV loans. In the down-rate

scenario, the difference is even greater. These differences in

performance between high and low LTV loans are much bigger than would

be expected in normal times. But the very poor credit conditions in the

stress test environment have a disproportionate effect on the more

vulnerable high LTV loans.

For seasoned loans, the effects of LTV are muted. Seasoned loans

with 50 percent LTVs reduce required capital less than comparable new

loans. Though credit losses are lower than those of newly originated

loans, the difference is minor, as credit losses are very low in both

cases. More importantly, the older loans amortize faster, reducing

guarantee fees significantly. For loans with 95 percent LTVs, the

difference in credit losses between seasoned and new loans is

substantial. With a 13.7 percent average house price appreciation since

origination, these seasoned 95 percent LTV loans perform only a little

bit worse than newly originated 80 percent LTV loans.

(v) Differences in Product Type and LTV Ratio

The simulations shown in Table 12 show the relative effects of

three different product types (30-year FRMs, 15-year FRMs, and

adjustable-rate mortgages) with low, medium, and high LTVs). All are

newly originated loans. To isolate the effects of loan type, the 7.5

percent contract loan rate was retained for the 15-year FRMs and is the

initial rate on the adjustable-rate mortgages (ARMs). The ARMs adjust

annually to 2.75 percentage points above the one-year constant maturity

Treasury yield, with a two percentage point annual adjustment cap and a

five percentage point lifetime cap.

[[Page 18105]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.197

The intermediate-term (15-year) FRMs have consistently lower credit

losses than long-term (30-year) FRMs because the shorter-term loans

amortize more quickly, and borrowers choosing those loans tend to have

greater financial resources. For 50 percent LTV loans, the difference

in credit losses is small, as credit losses are very low for loans of

both terms. In the up-rate scenario, the 30-year loans benefit from

slower amortization, which results in more guarantee fees. In both the

80 percent and 95 percent LTV categories, the more favorable

incremental capital effects of 15-year loans reflect their greater

safety. For 95 percent LTV loans, the 15-year loans have sharply lower

credit losses, nearly 90 percent below those of 30-year FRMs.

ARM loans are riskier than 30-year FRMs at all LTV levels in the

up-rate scenario, with the differences becoming more pronounced as LTV

ratios rise. ARM credit losses in the up-rate scenario are only

modestly higher than 30-year FRM credit losses for low LTV loans, but

rise to more than double those for 30-year FRMs for high LTV loans.

Credit losses for high LTV ARMs cumulate over the course of the stress

period to 13.5 percent of the initial loan balances. As the loan

interest rates adjust to their lifetime caps, some borrowers have

difficulty meeting the elevated payments.

When interest rates decline, ARMs perform much better. They prepay

much more slowly than FRMs in this environment and, therefore, produce

substantially more guarantee fee income. At low and moderate LTVs, ARMs

have more favorable capital effects than FRMs. However, the greater

sensitivity of defaults on ARMs with high initial LTVs outweighs the

benefits of higher fee income generated by such loans. While credit

losses for high LTV ARMs are still much lower in the down-rate scenario

than in the up-rate scenario, the discounted values of those losses are

larger in the down-rate scenario because the discount rates are so much

lower in that scenario. The capital effects depend on the discounted

values, so they are nearly as large in the down-rate scenario for high

LTV ARMs as they are in the up-rate scenario. Because of the high risk

associated with high LTV ARMs, the Enterprises generally have not

purchased ARMs with LTV ratios above 90 percent under their regular

underwriting guidelines.

(vi) Differences in Multifamily Loans

The Enterprises deal in a large variety of multifamily loan

products, and the products differ significantly between the

Enterprises. The simulations reported in Table 13 show the incremental

effects on required capital of multifamily loans with some relatively

common characteristics. The additional sold loans in Simulation 22 are

newly originated 15-year balloons with 70 percent LTVs, debt coverage

ratios (DCR) of 1.3.\44\ The Fannie Mae loans are assumed to provide

partial recourse to the seller for losses, while the Freddie Mac loans

do not. Accordingly, a higher guarantee fee is assumed for Freddie Mac

loans, 75 basis points, than for Fannie Mae loans, 50 basis points.

Simulations 23, 24, and 25 differ, respectively, by changing the

balloon to five years, changing the LTV to 80 percent and the DCR to

1.2, and changing the loan age to five years.

---------------------------------------------------------------------------

\44\ All of the multifamily loans were originated in the West

Census Region with 8.5 percent coupons and servicing margins of 50

basis points.

[[Page 18106]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.198

Unlike single family loans, multifamily loans with a few years of

seasoning have substantially higher credit losses during the stress

period. Both types of loans generally have low credit losses in the

first years after origination, then rise to a peak before declining.

However, the peak loss years for multifamily loans come several years

after those for single family loans. Thus, the five-year old loans in

Simulation 25 experience more bad loss years than comparable new loans

(Simulation 22). Credit losses for high LTV, low DCR loans (Simulation

23) are also higher than comparable lower LTV, higher DCR loans because

there is a higher probability that the borrower would have an economic

incentive to default during the stress period (no equity and negative

cash flow). Five-year balloons have higher losses in the up-rate

scenario because some properties would be unable to manage the higher

interest rates that would accompany a new loan. In the down-rate

scenario, five-year balloons terminate sooner and, thus, provide less

guarantee fee income.

Multifamily loan losses are generally less than guarantee fee

income in the down-rate scenario. This is especially true for newly

originated loans because most of the loans prepay before reaching their

peak loss years. Multifamily loans also benefit in the down-rate

scenario from lower capitalization rates, which improve their estimated

LTVs.

(vii) Differences in Mortgage Insurance on High LTV Loans

By law, conventional loans purchased by the Enterprises with LTVs

greater than 80 percent require credit enhancement. Of the three types

permitted, private mortgage insurance is by far the most commonly used.

As described above, simulations involving additional guarantees for

loans with 95 percent LTV ratios assume that the loans carry 30 percent

coverage by a AA rated firm. The simulations reported in Table 14 show

effects of varying insurance characteristics on single family loans.

The guarantee additions in each case are for newly originated, long-

term FRMs.

[GRAPHIC] [TIFF OMITTED] TP13AP99.199

In 1995, both Enterprises raised their coverage requirements on 95

percent LTV loans from 25 percent to 30 percent. Credit losses in

Simulation 26, with lower coverage than in Simulation 13 (but with all

other characteristics are the same), are 15 percent higher in the down-

rate scenario and 12 percent higher in the up-rate scenario than they

are in Simulation 13. Because the discounted value of those changes is

higher in the down-rate scenario, the

[[Page 18107]]

required capital is affected more significantly in that scenario.

Reducing the credit quality of the coverage (Simulation 28) has much

the same effect as reducing the amount of coverage, while improving the

credit quality (Simulation 27) has the opposite effect.

(viii) Differences in Mortgage Interest Rates

Loans with low interest rates amortize more quickly and prepay more

slowly. The reverse is true for high interest rate loans. Table 15

shows the results of simulations for newly originated, long-term FRMs

with different interest rates. In practice, loans with different

interest rates have been originated in different time periods. However,

to isolate the effects of different mortgage interest rates, all loans

are assumed to be made simultaneously.

[GRAPHIC] [TIFF OMITTED] TP13AP99.200

Faster amortization improves loan quality, so credit losses are

significantly lower for mortgages with low interest rates. Low interest

rate loans also prepay significantly more slowly in the down-rate

scenario, increasing guarantee fees. For Freddie Mac, these differences

between high and low mortgage interest rates are accentuated by

differences in float income. Freddie Mac holds prepayments for an extra

month before passing them through to investors. During that month,

Freddie Mac earns a market rate of return while paying investors at the

mortgage security coupon rate. Float earnings are roughly the same for

both high and low mortgage interest rates, but interest passthrough

payments to investors are much lower on low rate mortgages, increasing

net float income.

(ix) Differences Between Loans on Owner-Occupied and Investor-Owned

Properties

Loans on owner-occupied properties present less credit risk than

loans on investor-owned properties. Simulation 31, presented in Table

16, shows the effects on required capital of adding newly originated,

long-term fixed-rate mortgages that are all investor-owned. Required

capital for loans on investor-owned properties is substantially higher

in all cases because of higher credit losses.

[GRAPHIC] [TIFF OMITTED] TP13AP99.201

2. Commitments

While commitments to purchase mortgages may result in new mortgage

guarantees or new retained mortgages, the risk accepted by the

Enterprise at the time of commitment is comparable to the risk on new

mortgage guarantees. The stress test treats mortgages delivered

pursuant to commitments as guarantees of mortgages that are originated

in the first few months of the stress test at market interest rates.

Hence, no portfolio interest rate risk will be incurred. The mix of

other characteristics of the loans reflects the mix of characteristics

for existing guaranteed loans of the Enterprise that

[[Page 18108]]

were originated during the six months preceding the start of the stress

period.

Simulation 32, shown in Table 17, shows the effects on required

capital of increasing each Enterprise's commitments outstanding in June

1997 by $10 billion. The results are, essentially, an average of the

effects on required capital of a mixture of new loans, in which the

proportions of loans with particular characteristics (including

guarantee fees) match those present in an Enterprise's recently

originated and securitized loans. In the up-rate scenario, the effects

are muted relative to those in the down-rate scenario because the model

assumes that sellers deliver loans for only 75 percent of the

commitment volumes.

[GRAPHIC] [TIFF OMITTED] TP13AP99.202

3. Assets and Liabilities

The Enterprises' other line of business is purchasing mortgages and

mortgage securities for their asset portfolios and funding them with

debt. As holders of mortgages, the Enterprises receive interest income,

incur administrative expenses, and bear the risk of loss if a borrower

defaults. As market interest rates change, the interest rate of a

mortgage becomes more or less favorable, and the value of the mortgage

will change. The Enterprises hedge this risk by issuing callable long-

term debt, which changes in value in a corresponding way. They also

enter into interest rate derivative contracts that further reduce the

overall sensitivity of their income and net worth to interest rate

changes. As a holder of mortgage securities, an Enterprise experiences

cash flows, income, and risks similar to those experienced as a holder

of whole mortgages except that the credit risk is borne by the security

guarantor (usually the Enterprise itself, acting in its other principal

role).

The stress test projects the flows of income and expenses

associated with these assets in much the same way as it does for

mortgage guarantees. However, principal and interest received by an

Enterprise on retained mortgages and mortgage securities is not passed

on to investors, and no credit losses are charged on asset holdings of

mortgage securities guaranteed by either Enterprise or by the

Government National Mortgage Association (Ginnie Mae). In addition, the

stress test projects interest expenses associated with debt and cash

flows associated with derivatives contracts.

a. Assets/Liabilities With Mixed Characteristics Reflecting Enterprise

Portfolios

Table 18 shows the additional capital that would be required in

both scenarios by a general increase in each Enterprise's assets and

liabilities. It is not possible to isolate the average incremental

capital effects of a general increase in an Enterprise's mortgage

assets in the same way that Simulation 1 measured those effects for

guaranteed mortgages. Critical factors in assessing the risk of asset

positions are the characteristics of the debt and equity used to fund

them. However, specific debt and equity issues cannot be matched with

specific assets. It is possible, however, to obtain a measure of the

incremental capital effects of a proportional $10 billion increase in

all of an Enterprise's assets, including non-mortgage assets, and a

simultaneous $10 billion increase in the Enterprise's liabilities and

interest rate derivatives.\45\

---------------------------------------------------------------------------

\45\ The process is indirect, using the results of other

simulations. The increase in required capital for an equal

percentage increase in all of an Enterprise's positions, such that

assets increase by $10 billion, is simply that percentage of the

Enterprise's required capital for the base case simulations for June

1997. This increase includes increases in guarantees and

commitments. The effect of these increases can be removed by

subtracting the incremental effects of the guarantees and

commitments as calculated in Simulations 1 and 32, after making

adjustments for the differences between a $10 billion change in

those factors and a change of the percentage amount used in the

first step.

[GRAPHIC] [TIFF OMITTED] TP13AP99.203

These results reflect some differences between the Enterprises in

asset composition, but, mostly, differences in debt structure and

derivatives use in June 1997. In three of the four cases, the

incremental effects are close to or less

[[Page 18109]]

than the 2.50 percent minimum capital ratio for Enterprise assets. For

both Enterprises, the incremental required capital effects of sold

loans were higher in the down-rate scenario while the effects of asset

holdings and liabilities are higher in the up-rate scenario. Thus, the

combined risks of both types of activities are more balanced with

respect to interest rates than the risks of either type separately.

b. Retained Loans With Specific Identical Risk Characteristics

The simulations discussed below show the effect on required capital

of an increase in mortgage assets that is funded by debt. A first group

of simulations shows how different characteristics of mortgages affect

required capital in each scenario. Five-year, fixed-rate notes were

used to fund mortgage assets in each of these simulations. Different

funding would not have an appreciable effect on the relative results

for mortgages of differing characteristics, as long as the funding was

the same for each. In the second group of simulations, mortgage

characteristics were held constant, while the funding varied among

three alternatives.

The Enterprises have available, and utilize, a much wider range of

funding alternatives than those used in these simulations. These

alternatives include debt (both callable and non-callable) of different

maturities, debt-derivative combinations that create synthetic debt

with various maturity and call characteristics, and debt combined with

swaptions (options on swaps) or with interest rate caps, floors, or

corridors. Other hedging techniques, such as asset swaps, are also

used. The proposed risk-based capital requirements are fully sensitive

to all of these alternatives.

In the Simulations presented in Table 19, $10 billion of retained

unsecuritized loans with specific risk characteristics were added to

each Enterprise's asset portfolio. The assets were funded with $10

billion of five-year notes paying 6.5 percent interest, with no call

options. The mortgages in Simulation 33 have the same characteristics

as those in Simulation 2, except they have not been securitized. They

are newly originated 30-year fixed-rate mortgages, with 80 percent LTV

ratios and 7.5 percent contract interest rates from the West South

Central Census Division. In Simulations 34 through 39, one risk

characteristic (mortgage type, LTV, or age) has been changed from

Simulation 29 to illustrate the relative effects on required capital of

changes in various characteristics.\46\

---------------------------------------------------------------------------

\46\ While these results are for additional retained whole

loans, the effects on required capital of additional holdings of

mortgage security assets, backed by loans with the same

characteristics and funded with the same debt, can be closely

approximated by subtracting the effects of additional guarantees of

loans with those characteristics. (The comparable loan guarantee

simulations are Simulations 2, 17, 20, 12, 13, 5, and 7

respectively.)

[GRAPHIC] [TIFF OMITTED] TP13AP99.204

As the results make clear, using solely five-year fixed-rate debt

to fund mortgages would not be an appropriate funding strategy to guard

against the risk of large, sustained changes in interest rates like

those incorporated in the stress test. When market interest rates

decline, fixed-rate mortgages prepay rapidly, and the five-year debt is

outstanding far longer than most of the mortgages it originally funded.

When market yields rise, fixed-rate mortgages prepay slowly, and the

debt matures long before most of the mortgages are liquidated.

In the up-rate scenario, ARMs with fixed-rate funding reduce

required capital because interest income rises with market yields

(until lifetime caps are reached), while funding costs remain unchanged

during the first five years. Differences in the impact on required

capital of fixed-rate mortgages of different types in the up-rate

scenario primarily reflect differences in credit losses. However, 15-

year loans also benefit from faster amortization, making their loan

lives correspond more closely to the maturity of the debt used to fund

them.

[[Page 18110]]

In the down-rate scenario, ARMs prepay more slowly than FRMs, but

also provide lower interest income. Among fixed-rate types of loans,

four-year-old loans prepay more rapidly than new or eight-year-old

loans. High-LTV loans, on the other hand, prepay slowly because

borrowers lack sufficient equity for refinancing. These differences in

prepayment rates greatly affect the interest rate risk characteristics

of the loans, so that if they are funded with the same liabilities,

four-year old loans with 80 percent LTVs generate higher capital needs

in down-rate scenario than new loans with 95 percent LTVs, despite much

lower credit losses.

The proposed capital requirements are very sensitive to differences

in funding strategies for mortgage assets because of the magnitude of

the interest rate changes in the two scenarios. Table 20 shows the

results of three alternative funding choices for newly originated long-

term FRMs with 80 percent LTVs like those in Simulation 33.

[GRAPHIC] [TIFF OMITTED] TP13AP99.205

Funding long-term FRMs with short-term debt (six-month discount

notes) provides very substantial benefits when interest rates fall. The

debt matures more rapidly than the mortgages, permitting an Enterprise

to continue receiving the original yield on the mortgages, while paying

much lower interest rates. Short-term funding, though, is extremely

costly when interest rates rise because maturing debt must be replaced

at much higher rates. A portfolio of long-term fixed-rate mortgages

funded with short-term debt, such as those held by Fannie Mae and most

thrifts in the late 1970s, would require a capital/asset ratio of well

over 20 percent under the proposed rule.

Funding with long-term debt (ten-year notes with semi-annual

interest payments at 6\3/4\ percent) provides large benefits when

interest rates rise, but is extremely costly when interest rates fall.

Callable long-term debt (ten-year maturity, with a coupon of 7\3/8\

percent, not callable during the first two years) provides benefits in

both scenarios.\47\ The results for different funding mixes can be

approximated by combining the results shown in Table 20 on a weighted

average basis. Thus, for example, in June 1997, the incremental capital

effects of new fixed-rate mortgages funded with 65 percent callable

long-term debt, 19 percent short-term debt, and 16 percent long-term,

non-callable debt would be in a range of 1.2 percent to 2.6 percent for

both Enterprises in both interest rate scenarios. Less callable debt

would be needed to achieve the same result for seasoned loans.

---------------------------------------------------------------------------

\47\ The interest rates of long-term debt used in the

simulations roughly reflect what the average cost of such

instruments would have been in June 1997.

---------------------------------------------------------------------------

4. Administrative Costs

During the stress period, administrative costs depend not only on

the volume of loans held or guaranteed, but also on the rate of

spending in the quarter immediately preceding the start of the stress

period. A higher rate of administrative expense before the stress

period increases costs and depletes capital during the stress period.

In Simulation 43, shown in Table 21, $10 million in annual

administrative expense ($2.5 million at a quarterly rate) was added to

each Enterprise's reported spending in the year preceding the date of

the base case simulations (June 1997).

[GRAPHIC] [TIFF OMITTED] TP13AP99.206

The results in Table 21 show that if Fannie Mae's annual

administrative expense rate had been $1 higher in the year preceding

the stress period, its capital requirement would have been $5.92 higher

in the up-rate scenario and $3.53 higher in the down-rate scenario. The

stress test projects the higher expense rate to continue throughout the

[[Page 18111]]

ten years of the stress period, except that the dollar amount of

additional expense declines in line with the outstanding loan volume.

Thus, in the up-rate scenario, for example, the initial annual $1

increase in the expense rate leads to an additional $7.65 of

administrative expenses during the stress period. Discounting, taxes,

and dividends reduce the incremental required capital to $5.92, even

after the 30 percent management and operations risk supplement.

Required capital increases more in the up-rate scenario than the down-

rate scenario because administrative expense is tied in the stress test

to outstanding loan volumes, which are larger in the up-rate scenario.

The effect of increased administrative expenses on required capital

is lower for Freddie Mac in both interest rate scenarios. This is true

partly because Freddie Mac's mortgages have slightly shorter lives in

both interest rate scenarios, but more importantly because Fannie Mae

has disproportionately larger commitments outstanding at the start of

the stress period. As commitments are transformed into loans during the

early months of the stress period, Fannie Mae's overall loan balances

rise relative to initial balances by more than Freddie Mac's. This

effect is less significant in the up-rate scenario because only 75

percent of commitments become loans. However, Freddie Mac's costs in

the up-rate scenario are reduced by taxes throughout the stress period,

while Fannie Mae's are not. Therefore, Freddie Mac's administrative

expense rate has a smaller effect on required capital in both interest

rate scenarios.

5. External Economic Conditions

a. House Prices

Stress test results are also greatly affected by changes in

external economic conditions. Seasoned mortgages in the base case

simulations for June 1997 benefited from modest, but steady average

house price appreciation of about three percent per year during the

time between origination and the beginning of the stress period. In

Simulations 46 and 47, shown in Table 22, the house price index was

reduced by one percent and five percent, respectively, in the quarter

immediately preceding the stress period (1997 Q2). That is, house price

appreciation rates between the first and second quarters of 1997 were

assumed to be one percentage point or five percentage points (4 or 20

percentage points at an annual rate) less than they actually were.

Subsequent house price appreciation rates are the same as in previous

simulations.

[GRAPHIC] [TIFF OMITTED] TP13AP99.207

When house prices are decreased by one percent, credit losses for

each Enterprise increase by four to five percent in the up-rate

scenario and by about seven percent in the down-rate scenario. The

increases in credit losses when house prices are decreased by five

percent are about five times as large as they are for a one percent

house price decrease. The increases in incremental capital in both

simulations are larger in the down-rate scenario because the decrease

in house prices slows prepayment rates in that scenario, owing to

higher probabilities of negative equity. Slower prepayment rates

increase the volume of mortgages exposed to the risk of default. While

loans also prepay more slowly in the up-rate scenario, prepayment rates

in the base case simulation for that scenario are already so slow that

a similar percentage change has little absolute effect.

The slowing of prepayment rates with lower house prices in the

down-rate scenario also produces two benefits that offset much of the

increase in loan losses: guarantee fee income and net interest income

increase. The key factor causing the effects on required capital to be

larger in the down-rate scenario is that discount rates are lower in

that scenario, so the present value of similar additional credit losses

is greater.

Differences in the changes in required capital between the

Enterprises primarily reflect lower additional credit losses for

Freddie Mac. Fannie Mae's losses are higher because its owned or

guaranteed loan volume was about 45 percent larger than Freddie Mac's

in June 1997 and its credit losses per dollar of loans are 11 to 14

percent higher in the simulations, owing to a somewhat riskier mix of

loans.

b. Market Interest Rates

The behavior of interest rates in the months before the starting

date of the stress test can also have a significant effect on required

capital. In the simulations shown in Table 23, all market yields were

assumed to be 200 basis points higher (Simulation 46), or lower

(Simulation 47) in the month preceding the stress test period (June

1997) than they actually were.\48\ The principal means by which this

change in market yields affects required capital is through the change

it causes in market interest rates during the last nine years of the

stress test.\49\

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\48\ No changes were made to interest rates on asset, liability,

or off-balance sheet positions that had been put in place during the

month, but they constitute a small share of total positions, and the

effects of adjusting interest rates for those positions would have

been largely offsetting. Nor were any changes made to Enterprise

hedge positions that they might have made had market yields actually

changed.

\49\ In the circumstances of June 1997 (or any other time since

September 1991), the applicable statutory rule for determining the

change in the ten-year constant maturity Treasury yield during the

stress period is that it increases by 75 percent or decreases by 50

percent from the average over the preceding nine months. If interest

rates were 200 basis points higher in June 1997, stress test rates

would have risen to a level 200 9 x 1.75 = 39 basis

points higher for the last nine years in the up-rate scenario. And,

in the down-rate scenario, rates would have decreased to a level 200

9 x 0.50 = 11 basis points higher. Similarly, if interest

rates were 200 basis points lower in June 1997, stress test rates

would have been 39 basis points lower in the last nine years of the

up-rate scenario and would have fallen to a level 11 basis points

lower in the last nine years of the down-rate scenario. These

differences are incorporated in Simulations 46 and 47.

[[Page 18112]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.208

In Simulation 46, the hypothetical increases in June 1997 yields

make the stress test more severe in the up-rate scenario and less

severe in the down-rate scenario. Simulation 47 does the reverse. The

size of the effects is much greater for Fannie Mae because its asset

size was roughly double Freddie Mac's at the time, and because Fannie

Mae's interest rate risk was less fully hedged then Freddie Mac's.

Although changes in net interest income accounted for nearly all of the

change in required capital, differences in prepayment rates in the

down-rate scenarios of both simulations affected required capital

through changes in other income and expense categories. Lower

prepayment rates in Simulation 46 increased credit losses, but also

increased guarantee fees. Higher prepayment rates in Simulation 47

decreased credit losses and guarantee fees.

c. Sensitivity to Risk Characteristics in Different Economic

Environments

The results of the sensitivity analysis discussed above are

dependent on the risk structure of the Enterprises and the economic

conditions of June 1997. For example, as discussed above, credit losses

on seasoned loans vary depending on house price behavior between the

time of origination and the start of the stress test. At higher

interest rate levels, the consequences of imperfectly matched assets

and liabilities would be greater because stress test changes in

interest rates would be larger. At lower interest rate levels, the

effects would be smaller. Different Enterprise hedging strategies could

affect reported sensitivities because they could result in a different

pattern of profits and losses during the stress period, which could

affect the role of taxes. Changes in common stock dividend payouts

could affect the impact of dividends during the first year of the

simulations.

C. Implications of the Proposed Rule

The Enterprises perform an important role in the nation's housing

finance system. Although the current risk of an Enterprise failure is

small, the continued financial health of the Enterprises cannot be

taken for granted. Over the past two decades, failures of financial

institutions have been commonplace, including more than 2900 banks and

thrifts and a number of securities firms. The risks associated with

Fannie Mae and Freddie Mac differ in some important ways from those

associated with banks, thrifts, and securities firms. However,

government sponsored enterprises are not immune to failure. Fannie Mae

encountered serious financial difficulty in the early 1980s, recovering

in large part because of a fortuitous decline in interest rates, and

the Farm Credit System experienced serious problems later in the

decade. Because of the Enterprises' key role and important public

mission, Congress created OFHEO to ensure their safe and sound

operation. The current combined obligations of the Enterprises amount

to more than $1.7 trillion, and unlike banks, thrifts, and securities

firms, no Enterprise obligations are backed by an insurance fund that

could contribute toward meeting creditor claims.

The risk-based capital rule (in conjunction with OFHEO's other

regulatory tools) is intended to reduce the risk of financial failure

of an Enterprise. The rule can contribute to that goal by requiring the

Enterprises to hold more capital or take less risk than they otherwise

would in some or most potential circumstances, particularly those

circumstances in which the danger of failure is greatest. In

circumstances in which some capital or risk adjustment is necessary,

the rule gives an Enterprise the flexibility to choose whether more

capital, less risk, or a combination of the two best suits its business

needs.

OFHEO believes that the proposed rule would effectively serve its

intended role. By promoting the Enterprises' safety and soundness, the

regulation promotes their ability to continue to carry out their public

purposes.\50\ These include providing stability in the secondary market

for residential mortgages and providing access to mortgage credit in

central cities, rural areas, and underserved areas.

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\50\ 1992 Act, section 1302(2) (12 U.S.C. 4501(2)).

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Capital reduces the risk and costs of failure by absorbing losses.

For most firms, debt markets provide strong capital discipline,

penalizing a firm that is excessively leveraged with higher borrowing

costs. That discipline is largely lacking for the Enterprises because

of their government sponsored enterprise status. The lack of normal

market discipline makes capital requirements particularly important for

the Enterprises.

The minimum capital regulation, currently in place for the

Enterprises, provides important protection against failure. It requires

the Enterprises to have a minimally acceptable level of capital in

relation to their overall size, regardless of their measurable risk.

The establishment of the minimum capital standard was accompanied by

considerable increases in capital at both Enterprises. Because,

however, it is based on simple leverage ratios, it will not be

sufficient if an Enterprise chooses to take risky financial positions

or if market conditions move adversely and increase the risk of what

had been less risky positions. By contrast, the proposed rule is quite

sensitive to risk. It would require an Enterprise to increase capital

when risk rises, well before the potential adverse

[[Page 18113]]

consequences of the rise would be reflected in the Enterprise's

financial statements. Each of the two capital rules is an essential

complement to the other.

1. Capital Requirements Under the Proposed Rule

Consistent with the purpose of reducing the risk of Enterprise

failure, the proposed rule can be expected to influence how the

Enterprises manage their risk and the amount of capital they hold.

Table 24 shows actual total capital (amounts available to meet the

risk-based capital requirement) and required total capital under the

proposed rule for two dates: September 30, 1996 and June 30, 1997.\51\

It also shows actual core capital (amounts available to meet the

minimum capital requirement) and required core capital on the same

dates. The difference between total capital and core capital is that

total capital includes general loss reserves, while core capital does

not.

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\51\ These results include estimated effects on required total

capital for three provisions of the proposed rule that require

credit ratings: credit losses on non-mortgage investments; on

derivative contracts; and on rated mortgage-related securities, such

as mortgage revenue bonds. OFHEO assumed that 50 percent of non-

mortgage investments are rated AAA, 35 percent are rated AA, and 15

percent are rated A. The percentages for derivative contracts are

85, 15, and 0, respectively; and those for rated mortgage-related

securities are 70, 30, and 0, respectively. The results do not

reflect the effects of master netting agreements, nor haircuts on

foreign-denominated contracts. Multifamily credit enhancements,

other than those for Fannie Mae's DUS product are not modeled

explicitly, but are assumed to reduce loss severities by 15.9

percentage points.

[GRAPHIC] [TIFF OMITTED] TP13AP99.209

Table 25 shows the surplus or deficit of total capital for both

interest rate scenarios. The risk-based capital requirement for an

Enterprise is based on the scenario that would result in the greatest

deficit or smallest surplus. To meet the requirement, an Enterprise

must not have a capital deficit in either scenario. Freddie Mac would

have had a risk-based capital surplus of 28 percent on the 1996 date

and 19 percent in 1997, while Fannie Mae would have had a deficit on

each date of 21 percent. In contrast, both firms met the existing

minimum capital standard on both dates, with surpluses ranging from 4

percent to 11 percent. Thus, the risk-based capital requirement would

have been much higher than the minimum capital requirement for Fannie

Mae, even after taking account of the differences in the definition of

capital under the two standards. For Freddie Mac, however, the minimum

capital requirement would have been higher than the risk-based capital

requirement. Thus, the risk-based standard would not have imposed any

additional requirement on Freddie Mac on those dates. The primary

reason Fannie Mae's risk-based capital requirement would have exceeded

its minimum capital requirement, while Freddie Mac's would not, is that

Freddie Mac's asset/liability structure was more fully hedged against

interest rate risk than Fannie Mae's.

[[Page 18114]]

[GRAPHIC] [TIFF OMITTED] TP13AP99.210

Risk-based capital requirements in the future may vary

significantly, depending not only on the Enterprises' assets and

obligations, but also on contemporary economic conditions. Declines in

house prices in the years preceding the starting date of the stress

test can greatly raise capital requirements under the proposed rule,

and rapid house price appreciation during these years can greatly

reduce them. Unhedged interest rate exposures would require greater

capital when interest rates are higher at the start of the stress

period because changes in interest rates during the stress period will

be greater. The reverse is true when interest rates are lower. Economic

environments entailing greater than usual uncertainty about future

interest rates or mortgage defaults will be accompanied by higher costs

for hedges, such as callable debt or credit enhancements. In the

absence of a risk-based capital standard, an Enterprise might choose to

maintain capital and hedges that would be sufficient to meet the

proposed standard in low risk environments, but might not do so in high

risk environments owing to the higher cost of capital and hedges in

such environments.

2. Enterprise Adjustments To Meet the Proposed Standard

An Enterprise with capital and risk preferences that are not

consistent with the proposed standard could adjust to the standard by

either increasing capital or decreasing risk or both. Capital can be

increased by reducing share repurchases, adjusting dividends, or

issuing new equity shares. Enterprise risk can be reduced by increasing

the use of interest rate and credit risk hedges, after risk is taken

on, or by reducing the amount of risk taken on.

Financial markets currently provide a wide range of hedges against

interest rate risk. These include, among others: callable long-term

debt, caps and floors, and swaps and swaptions. Adding interest rate

risk hedges may frequently be cheaper than increasing equity. For

example, based on the differences in results of Simulations 40, 41, and

42 shown in Table 20, Fannie Mae could have met the proposed standard

in June 1997 by issuing $22 billion of callable ten-year notes and

using the proceeds to pay off $14 billion of short-term debt and

repurchase $8 billion of ten-year notes.\52\ Given the market yields at

that time, such a change in debt structure would have cost less than

$200 million on an annual basis, after taxes. However, because this

debt restructuring would have provided substantial benefits in terms of

reduced risk, the net cost would have been much lower.

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\52\ The interest rates of long-term debt used in the

simulations roughly reflect what the average cost of such

instruments would have been in June 1997.

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Changes in an Enterprise's asset/liability structure to reduce

interest rate risk, such as the one described in the above example, may

be much cheaper than raising new equity. If the annual cost of equity

capital is assumed to be 15 percent, the net cost of raising sufficient

equity would have been roughly $385 million.\53\ Other forms of

liability restructuring, or changes in the interest rate risk

characteristics of the assets, might have resulted in lower costs than

those estimated here for hypothetical changes in debt structure. Fannie

Mae anticipated the likelihood of such opportunities in its comment on

OFHEO's ANPR: ``* * * if the [mortgage] portfolio is in a position

where its risk-based capital requirement exceeds its actual capital,

the practical remedy would be to change the portfolio's asset/liability

structure so that this is no longer the case.'' An alternative way for

an Enterprise to reduce its interest rate risk is simply to reduce the

size of its asset portfolio. Given the high profitability of those

portfolios in recent years, that currently would not be a likely

choice.

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\53\ In its analysis supporting its affordable housing goal

rule, HUD used an estimate for the cost of equity capital of 17

percent, but subsequent increases in price-earnings ratios suggest a

smaller number for more recent dates. The cost calculation assumes

that the additional equity would have replaced an equal amount of

debt.

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Increasingly, credit risk can also be hedged in financial markets.

Freddie Mac's 1998 MODERNS transaction effectively transferred a

portion of the credit risk on its 1996 mortgage purchases to investors

in the new securities.\54\ Further development of the credit

derivatives market may provide additional opportunities for

transferring credit risk in the future. An Enterprise can also reduce

its credit risk by requiring or ac

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Risk-Based Capital · 64 FR 18084 | Frix