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	<title>Comments on: Fannie and Freddie: Conservatorship as Endgame?</title>
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		<title>By: ruetheday</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11074</link>
		<dc:creator>ruetheday</dc:creator>
		<pubDate>Fri, 11 Jul 2008 20:16:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11074</guid>
		<description>And now Bernanke is extending access to the discount window to both Fannie and Freddie.&lt;br/&gt;&lt;br/&gt;Kinda hard to jive such a measure with their managements&#039; insistence that &quot;we&#039;re adequately capitalized&quot;.</description>
		<content:encoded><![CDATA[<p>And now Bernanke is extending access to the discount window to both Fannie and Freddie.</p>
<p>Kinda hard to jive such a measure with their managements&#8217; insistence that &#8220;we&#8217;re adequately capitalized&#8221;.</p>
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		<title>By: malabar</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11068</link>
		<dc:creator>malabar</dc:creator>
		<pubDate>Fri, 11 Jul 2008 17:29:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11068</guid>
		<description>Those waterfall charts of FNM, FRE, LEH, WB, DSL, WM, FED, ....&lt;br/&gt;&lt;br/&gt;This is what happens when easy money and bailout nation becomes the governing philosophy of crony capitalism. Billion dollar bonuses for Wall Street elites, millions of dollars of contributions to politicians of both parties and of course the revolving door between regulators, policy makers and Wall Street. Rubin, Paulson, Easy Al.&lt;br/&gt;&lt;br/&gt;Now the biggest cheerleaders for &quot;free market capitalism&quot; and the repeal of Glass-Steagall and &quot;risk adjusted capital&quot; make even the marxist lenninist communists blush as they scream for nationalization, backstops and bailouts of their losing positions. But those billions in bonuses based on fraudulent financial performance - that&#039;s in the Cayman! &lt;br/&gt;&lt;br/&gt;Yes, the shoe is on the other foot!</description>
		<content:encoded><![CDATA[<p>Those waterfall charts of FNM, FRE, LEH, WB, DSL, WM, FED, &#8230;.</p>
<p>This is what happens when easy money and bailout nation becomes the governing philosophy of crony capitalism. Billion dollar bonuses for Wall Street elites, millions of dollars of contributions to politicians of both parties and of course the revolving door between regulators, policy makers and Wall Street. Rubin, Paulson, Easy Al.</p>
<p>Now the biggest cheerleaders for &#8220;free market capitalism&#8221; and the repeal of Glass-Steagall and &#8220;risk adjusted capital&#8221; make even the marxist lenninist communists blush as they scream for nationalization, backstops and bailouts of their losing positions. But those billions in bonuses based on fraudulent financial performance &#8211; that&#8217;s in the Cayman! </p>
<p>Yes, the shoe is on the other foot!</p>
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		<title>By: RueTheDay</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11062</link>
		<dc:creator>RueTheDay</dc:creator>
		<pubDate>Fri, 11 Jul 2008 15:26:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11062</guid>
		<description>A bailout is definitely coming in some shape or form but talk of secret backroom deals ala Bear is just silly.  The Fed, Treasury, etc. do not have the authority to arrange a takeover of FNM and FRE and even if they did, there&#039;s no one out there big enough to play the role of a JPM apart from the Federal Government itself.</description>
		<content:encoded><![CDATA[<p>A bailout is definitely coming in some shape or form but talk of secret backroom deals ala Bear is just silly.  The Fed, Treasury, etc. do not have the authority to arrange a takeover of FNM and FRE and even if they did, there&#8217;s no one out there big enough to play the role of a JPM apart from the Federal Government itself.</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11058</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Fri, 11 Jul 2008 13:24:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11058</guid>
		<description>&quot;A hedge fund guy sent me a newsletter which worked through what happens if either of the GSEs is put into custodianship or otherwise bailed out. Gold goes through the roof and the dollar and stock markets plummet. The language was far more extreme than what I just wrote, BTW.&quot;&lt;br/&gt;&lt;br/&gt;I&#039;d like to read that personally. I&#039;m looking for some future predictions on this. Could you post it?</description>
		<content:encoded><![CDATA[<p>&#8220;A hedge fund guy sent me a newsletter which worked through what happens if either of the GSEs is put into custodianship or otherwise bailed out. Gold goes through the roof and the dollar and stock markets plummet. The language was far more extreme than what I just wrote, BTW.&#8221;</p>
<p>I&#8217;d like to read that personally. I&#8217;m looking for some future predictions on this. Could you post it?</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11054</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Fri, 11 Jul 2008 12:22:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11054</guid>
		<description>Pre market Friday Fanny -42% her fat little bro Freddie -41% These guy are zeros, Bond holders will get there explicit guarantee. Trillion dollars for bond holders to short these clowns out of bussiness is really was very cheap.</description>
		<content:encoded><![CDATA[<p>Pre market Friday Fanny -42% her fat little bro Freddie -41% These guy are zeros, Bond holders will get there explicit guarantee. Trillion dollars for bond holders to short these clowns out of bussiness is really was very cheap.</p>
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		<title>By: Hubert</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11050</link>
		<dc:creator>Hubert</dc:creator>
		<pubDate>Fri, 11 Jul 2008 11:36:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11050</guid>
		<description>Yves &amp; all,&lt;br/&gt;&lt;br/&gt;so many question marks:&lt;br/&gt;Who is shorting F&amp;F equity into the ground?&lt;br/&gt;Why now?&lt;br/&gt;What hand is the administration playing here?&lt;br/&gt;How will Schumer/Dodd play along?&lt;br/&gt;&lt;br/&gt;It looks like an attempt from the Bushies to kill F&amp;F in a way that brings a lot of profits to bondholders while killing its stockholders. What is the political benefit of it? Money Funds and Banks would look better, Gov Bonds worse.&lt;br/&gt;&lt;br/&gt;COuld there be a deal with the Chinese? The shorting started after G-8.&lt;br/&gt;Chinese support Dollar and T-Bonds, Bush guarantess agency bonds and lets BB raise 25 in automn?</description>
		<content:encoded><![CDATA[<p>Yves &#038; all,</p>
<p>so many question marks:<br />Who is shorting F&#038;F equity into the ground?<br />Why now?<br />What hand is the administration playing here?<br />How will Schumer/Dodd play along?</p>
<p>It looks like an attempt from the Bushies to kill F&#038;F in a way that brings a lot of profits to bondholders while killing its stockholders. What is the political benefit of it? Money Funds and Banks would look better, Gov Bonds worse.</p>
<p>COuld there be a deal with the Chinese? The shorting started after G-8.<br />Chinese support Dollar and T-Bonds, Bush guarantess agency bonds and lets BB raise 25 in automn?</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11046</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Fri, 11 Jul 2008 09:45:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11046</guid>
		<description>Regulators are whistling past the graveyard (GSEs &quot;adequately capitalized&quot;), but with F&amp;F paying spreads on their debt corresponding to a five-levels-lower credit rating, their business model doesn&#039;t work, any more than Bear Stearn&#039;s did. Simply put, if CONfidence fails, they can&#039;t soldier on.&lt;br/&gt;&lt;br/&gt;And how does OFHEO get off saying that $80 billion capital to support $5 trillion in assets and guarantees is &quot;adequate&quot;? Setting capital requirements is arbitrary, but using the 8% guideline applied to banks, shouldn&#039;t F&amp;F have more like $400 billion capital to support their risky business? (Mortgages inherently have much gnarlier trading characteristics than straight bonds, owing to early payoff risk which is impossible to quantify exactly.)&lt;br/&gt;&lt;br/&gt;Tragically and predictably, the &quot;too big to fail&quot; doctrine is already being invoked. But why do we need F&amp;F? Within this decade, both companies got their accounting in a twist over derivatives, had to be audited and restate earnings, dumped CEOs, etc. Now the teetering mismanaged behemoths threaten the dollar and the credit rating of USGOV itself. If this is success, I&#039;d sure hate to see what failure looks like. (A question CONgress should ask itself, with its towering nine (9) percent approval rating.)&lt;br/&gt;&lt;br/&gt;I have been looking for an iconic bankruptcy to put a period under this twilight interlude of financial distress -- a household-name bank or industrial company. Who would have thunk that it might be Freddie Mac? Freddie, we hardly knew ye!</description>
		<content:encoded><![CDATA[<p>Regulators are whistling past the graveyard (GSEs &#8220;adequately capitalized&#8221;), but with F&#038;F paying spreads on their debt corresponding to a five-levels-lower credit rating, their business model doesn&#8217;t work, any more than Bear Stearn&#8217;s did. Simply put, if CONfidence fails, they can&#8217;t soldier on.</p>
<p>And how does OFHEO get off saying that $80 billion capital to support $5 trillion in assets and guarantees is &#8220;adequate&#8221;? Setting capital requirements is arbitrary, but using the 8% guideline applied to banks, shouldn&#8217;t F&#038;F have more like $400 billion capital to support their risky business? (Mortgages inherently have much gnarlier trading characteristics than straight bonds, owing to early payoff risk which is impossible to quantify exactly.)</p>
<p>Tragically and predictably, the &#8220;too big to fail&#8221; doctrine is already being invoked. But why do we need F&#038;F? Within this decade, both companies got their accounting in a twist over derivatives, had to be audited and restate earnings, dumped CEOs, etc. Now the teetering mismanaged behemoths threaten the dollar and the credit rating of USGOV itself. If this is success, I&#8217;d sure hate to see what failure looks like. (A question CONgress should ask itself, with its towering nine (9) percent approval rating.)</p>
<p>I have been looking for an iconic bankruptcy to put a period under this twilight interlude of financial distress &#8212; a household-name bank or industrial company. Who would have thunk that it might be Freddie Mac? Freddie, we hardly knew ye!</p>
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		<title>By: Edward Harrison</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11045</link>
		<dc:creator>Edward Harrison</dc:creator>
		<pubDate>Fri, 11 Jul 2008 07:42:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11045</guid>
		<description>I will try a half coherent and typo-free response here as time is short.  &lt;br/&gt;You say:&lt;br/&gt;“In fact, the conspiracy theory I prefer is that this panic actually serves the Bushies&#039; interests, provided they can contain it (the problem is that Poole, always a loose cannon, weighed in at the worst possible time). They are very anti rescues of the housing market of any sort. If they can make everyone realize that Fannie and Freddie are too wobbly to do much (which is actually true, randomly the Administration does have the correct position on this one), they will be able to block housing bailout initiatives.”&lt;br/&gt;I agree.  That’s what I am getting at.  The Bush administration does not want to be seen as bailing anyone out. As you say, they are anti-rescues (although their language on that has changed of late). They would prefer a back-door version like the one being proposed and block the housing bailout initiative.  This is why I believe this plan had been drafted in outline form way before (Jan, March?).  Now they are only beginning to flesh out the details on that outline because of the market turmoil caused by Lehman and Poole.&lt;br/&gt;I don’t prefer theories.  It does remains to be seen what type of activities the GSEs have been in engaging in since March.  That said, it is purely conjecture on my part that they have been buying up lower quality assets.  Only time will tell.  I can’t imagine that the quality of the assets they are taking onboard is high given the housing market deterioration. I looked at the 3-page pdf that you linked to, but it obviously can’t give any measure of detail as to asset quality.  You will notice however that FNM alone funded $327 billion of new business in 2008, over $190 billion since March. In Table 3, they also purchased $18 billion of new MBS.  There’s plenty of scope there for taking on junkie assets.&lt;br/&gt;But that’s either here nor there. The crux of what I am saying lies in the fact that the plan to nationalize Fannie was one I believe made in March if not before.  Even if the two GSEs refused to buy up the mortgages to provide the necessary liquidity, then so be it.  The plan could still be drafted for the conservatorship nationalization as we have seen play out.&lt;br/&gt;The preferred route is a new authority for a bailout similar to the S&amp;L crisis or to the bank liquidator in the Swedish banking crisis of the early 1990s.&lt;br/&gt;You say:&lt;br/&gt;“FYI, my view has been if one must go this course, (and I am not a proponent) the way to do it would be via a new agency. You can&#039;t muddle the mission of bodies dedicated to at least attempting to do reasonably high quality loans with ones in the salvage business. They require different skill sets, and should have different financial structures too.”&lt;br/&gt;No argument here.&lt;br/&gt;As for the political pressure, what I see as persuasive pressure is a threat to re-intensify the call for tighter regulation of Fannie and Freddie. This was a time-consuming mind-numbing nightmare inside of the companies for well on three years.  The personal scrutiny was large as well. In the end, Freddie officials did have to cough up a decent amount of money.  SEC settlements were for $400,000 for former president David Glenn, $154,227 for former chief financial officer Vaughn Clarke, $136,663 for former senior vice president Nazir Dossani and $99,658 for former senior vice president Robert Dean. &lt;br/&gt;That’s really the only pressure that I mean.   Whether that would be enough pressure, I can’t say but your response about Dan Mudd’s not playing ball suggests it’s not enough.&lt;br/&gt;So my theory is no ‘conspiracy theory.’  It is simply electoral year attempts by a lame-duck administration to end-run around a housing bailout.  I hope that puts things in a less “second shooter on the grassy knoll” context.</description>
		<content:encoded><![CDATA[<p>I will try a half coherent and typo-free response here as time is short.  <br />You say:<br />“In fact, the conspiracy theory I prefer is that this panic actually serves the Bushies&#8217; interests, provided they can contain it (the problem is that Poole, always a loose cannon, weighed in at the worst possible time). They are very anti rescues of the housing market of any sort. If they can make everyone realize that Fannie and Freddie are too wobbly to do much (which is actually true, randomly the Administration does have the correct position on this one), they will be able to block housing bailout initiatives.”<br />I agree.  That’s what I am getting at.  The Bush administration does not want to be seen as bailing anyone out. As you say, they are anti-rescues (although their language on that has changed of late). They would prefer a back-door version like the one being proposed and block the housing bailout initiative.  This is why I believe this plan had been drafted in outline form way before (Jan, March?).  Now they are only beginning to flesh out the details on that outline because of the market turmoil caused by Lehman and Poole.<br />I don’t prefer theories.  It does remains to be seen what type of activities the GSEs have been in engaging in since March.  That said, it is purely conjecture on my part that they have been buying up lower quality assets.  Only time will tell.  I can’t imagine that the quality of the assets they are taking onboard is high given the housing market deterioration. I looked at the 3-page pdf that you linked to, but it obviously can’t give any measure of detail as to asset quality.  You will notice however that FNM alone funded $327 billion of new business in 2008, over $190 billion since March. In Table 3, they also purchased $18 billion of new MBS.  There’s plenty of scope there for taking on junkie assets.<br />But that’s either here nor there. The crux of what I am saying lies in the fact that the plan to nationalize Fannie was one I believe made in March if not before.  Even if the two GSEs refused to buy up the mortgages to provide the necessary liquidity, then so be it.  The plan could still be drafted for the conservatorship nationalization as we have seen play out.<br />The preferred route is a new authority for a bailout similar to the S&#038;L crisis or to the bank liquidator in the Swedish banking crisis of the early 1990s.<br />You say:<br />“FYI, my view has been if one must go this course, (and I am not a proponent) the way to do it would be via a new agency. You can&#8217;t muddle the mission of bodies dedicated to at least attempting to do reasonably high quality loans with ones in the salvage business. They require different skill sets, and should have different financial structures too.”<br />No argument here.<br />As for the political pressure, what I see as persuasive pressure is a threat to re-intensify the call for tighter regulation of Fannie and Freddie. This was a time-consuming mind-numbing nightmare inside of the companies for well on three years.  The personal scrutiny was large as well. In the end, Freddie officials did have to cough up a decent amount of money.  SEC settlements were for $400,000 for former president David Glenn, $154,227 for former chief financial officer Vaughn Clarke, $136,663 for former senior vice president Nazir Dossani and $99,658 for former senior vice president Robert Dean. <br />That’s really the only pressure that I mean.   Whether that would be enough pressure, I can’t say but your response about Dan Mudd’s not playing ball suggests it’s not enough.<br />So my theory is no ‘conspiracy theory.’  It is simply electoral year attempts by a lame-duck administration to end-run around a housing bailout.  I hope that puts things in a less “second shooter on the grassy knoll” context.</p>
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		<title>By: a</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11044</link>
		<dc:creator>a</dc:creator>
		<pubDate>Fri, 11 Jul 2008 07:17:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11044</guid>
		<description>&quot;my view has been if one must go this course, (and I am not a proponent) the way to do it would be via a new agency.&quot;&lt;br/&gt;&lt;br/&gt;And, I think, this will be much cheaper to the American taxpayer.  Worse for the IBs.  That&#039;s a twofer.</description>
		<content:encoded><![CDATA[<p>&#8220;my view has been if one must go this course, (and I am not a proponent) the way to do it would be via a new agency.&#8221;</p>
<p>And, I think, this will be much cheaper to the American taxpayer.  Worse for the IBs.  That&#8217;s a twofer.</p>
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		<title>By: Yves Smith</title>
		<link>http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as.html#comment-11043</link>
		<dc:creator>Yves Smith</dc:creator>
		<pubDate>Fri, 11 Jul 2008 07:01:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/07/fannie-and-freddie-conservatorship-as-endgame/#comment-11043</guid>
		<description>Ed,&lt;br/&gt;&lt;br/&gt;It appears you did not look at the activity reports even though the links were provided. They show both purchases and sales broken down by category. There is no evidence of unusual activity in March, April or May, and it would take a higher level of activity to have had much impact. But you prefer theories rather than seeing if the facts bear them out.&lt;br/&gt;&lt;br/&gt;You also failed to address what consideration could be offered to the managements of Freddie and Fannie.  They so far have been pretty intransigent. Mudd has been pressured to raise equity and has not done so to the degree desired. And as noted, they have only half heartedly (if at all) acted on Congress&#039; plans to have them rescue housing. &lt;br/&gt;&lt;br/&gt;I don&#039;t see how the Feds have any leverage over Freddie and Fannie. They know they will be bailed out. They also know in any kind of rescue scenario. per Paulson insisting on $2 per share for Bear (and recall that deal did require shareholder approval, while the Feds have statutory authority to put the GSEs into receivership) that their equity is worth nada in any kind of bailout. It is a political necessity that the shareholders, including management, are wiped out if taxpayers have to come to the rescue.&lt;br/&gt;&lt;br/&gt;Fannie and Freddie hold the cards. They win in a game of chicken until their position becomes completely untenable. No one will shut them down until absolutely necessary. A hedge fund guy sent me a newsletter which worked through what happens if either of the GSEs is put into custodianship or otherwise bailed out. Gold goes through the roof and the dollar and stock markets plummet. The language was far more extreme than what I just wrote, BTW.&lt;br/&gt;&lt;br/&gt;So management&#039;s best financial opportunity is to see if they can ride the housing crisis out as a semi-private enterprise. If they do, their stock holdings will recover. And as self-serving as that is, it&#039;s also in our collective best interest.&lt;br/&gt;&lt;br/&gt;So their covert resistance to the efforts to make them the rescuers of housing make perfect sense.&lt;br/&gt;&lt;br/&gt;In fact, the conspiracy theory I prefer is that this panic actually serves the Bushies&#039; interests, provided they can contain it (the problem is that Poole, always a loose cannon, weighed in at the worst possible time). They are very anti rescues of the housing market of any sort. If they can make everyone realize that Fannie and Freddie are too wobbly to do much (which is actually true, randomly the Administration does have the correct position on this one), they will be able to block housing bailout initiatives.&lt;br/&gt;&lt;br/&gt;FYI, my view has been if one must go this course, (and I am not a proponent) the way to do it would be via a new agency. You can&#039;t muddle the mission of bodies dedicated to at least attempting to do reasonably high quality loans with ones in the salvage business. They require different skill sets, and should have different financial structures too.</description>
		<content:encoded><![CDATA[<p>Ed,</p>
<p>It appears you did not look at the activity reports even though the links were provided. They show both purchases and sales broken down by category. There is no evidence of unusual activity in March, April or May, and it would take a higher level of activity to have had much impact. But you prefer theories rather than seeing if the facts bear them out.</p>
<p>You also failed to address what consideration could be offered to the managements of Freddie and Fannie.  They so far have been pretty intransigent. Mudd has been pressured to raise equity and has not done so to the degree desired. And as noted, they have only half heartedly (if at all) acted on Congress&#8217; plans to have them rescue housing. </p>
<p>I don&#8217;t see how the Feds have any leverage over Freddie and Fannie. They know they will be bailed out. They also know in any kind of rescue scenario. per Paulson insisting on $2 per share for Bear (and recall that deal did require shareholder approval, while the Feds have statutory authority to put the GSEs into receivership) that their equity is worth nada in any kind of bailout. It is a political necessity that the shareholders, including management, are wiped out if taxpayers have to come to the rescue.</p>
<p>Fannie and Freddie hold the cards. They win in a game of chicken until their position becomes completely untenable. No one will shut them down until absolutely necessary. A hedge fund guy sent me a newsletter which worked through what happens if either of the GSEs is put into custodianship or otherwise bailed out. Gold goes through the roof and the dollar and stock markets plummet. The language was far more extreme than what I just wrote, BTW.</p>
<p>So management&#8217;s best financial opportunity is to see if they can ride the housing crisis out as a semi-private enterprise. If they do, their stock holdings will recover. And as self-serving as that is, it&#8217;s also in our collective best interest.</p>
<p>So their covert resistance to the efforts to make them the rescuers of housing make perfect sense.</p>
<p>In fact, the conspiracy theory I prefer is that this panic actually serves the Bushies&#8217; interests, provided they can contain it (the problem is that Poole, always a loose cannon, weighed in at the worst possible time). They are very anti rescues of the housing market of any sort. If they can make everyone realize that Fannie and Freddie are too wobbly to do much (which is actually true, randomly the Administration does have the correct position on this one), they will be able to block housing bailout initiatives.</p>
<p>FYI, my view has been if one must go this course, (and I am not a proponent) the way to do it would be via a new agency. You can&#8217;t muddle the mission of bodies dedicated to at least attempting to do reasonably high quality loans with ones in the salvage business. They require different skill sets, and should have different financial structures too.</p>
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