Wednesday, January 08, 2020 9:27:05 AM
KThomp - you need to realize that HERA is written so as to have the FHFA be an independent agency especially for the parts of HERA that deal with FHFA as conservator. HERA does not have a severability clause. By changing the director to at-will removal, it will render all of HERA to be inconsistent with itself as currently written. Self consistency is mandatory in statutes. If SCOTUS accepts this case dont be surprised if HERA in total is ruled unconstitutional and sent back to Congress to amend based on the above.
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