Fannie Mae-No Politics (FNMA)

[GAK-]

The "30 day" window is my understanding of the provisions in HERA.

Under: 12 U.S. Code §?4513b. Prudential management and operations standards

(b)Failure to meet standards
(1)Plan requirement
(C)Deadlines for submission and review

The Director shall by regulation establish deadlines that—
(i)provide the regulated entities with reasonable time to submit plans required under subparagraph (A), and generally require a regulated entity to submit a plan not later than 30 days after the Director determines that the entity fails to meet any standard established under subsection (a); and
(ii)require the Director to act on plans expeditiously, and generally not later than 30 days after the plan is submitted.

https://www.law.cornell.edu/uscode/text/12/4513b

My understanding is that once the Capital Rule is finalized and adopted, the GSE's will immediately be classified as undercapitalized, and this will trigger a notification of "Failure to meet standards," which will lead to the overall 60 day (30 days + 30 days) process outlined above. Recently, Holden has suggested that as long as the PSPA is in place, the Treasury line of credit will prevents the GSE's from ever being formally classified as undercapitalized and failing to meet the standard. So, I guess that in order for this 60 day clock to start, you first need a 4th amendment, then a publishing of the Capital Rule, then the 60 days.

In order for the 60 days to all take place before inauguration, this process would have to start by 11/20 (This Friday). If FHFA sees the terminus ad quem as the SCOTUS ruling against them (after which Calabria would be removable by POTUS), and not the inauguration day, then they may gamble on a 60 day window before the end of March, which basically means they could wait until inauguration in order to start this 60 day clock (because they need to start it before Mnuchin leaves office).

Does all of that make sense?