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Sunday, 10/17/2021 11:21:34 PM

Sunday, October 17, 2021 11:21:34 PM

Post# of 794298
Comments on FHFA Rulemaking/Notice Number:RIN-2590-AB17
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https://www.fhfa.gov/SupervisionRegulation/Rules/Pages/Comment-List.aspx?RuleID=708


"Q: What are the goals of this conservatorship?

A: The purpose of appointing the Conservator is to preserve and conserve the Company’s assets and property and to put the Company in a sound and solvent condition. The goals of the conservatorship are to help restore confidence in the Company, enhance its capacity to fulfill its mission, and mitigate the systemic risk that has contributed directly to the instability in the current market. There is no reason for concern regarding the ongoing operations of the Company. The Company’s operation will not be impaired and business will continue without interruption."

How is that nobody cares about these official FHFA announcements and promises to We the People?

Do official FHFA announcements have any legal validity to hold FHFA accountable?

Administration, Congress, Judiciary and FHFA have lot to explain to People about their capricious decisions and rulings that have no historical precedence that have caused irreparable damage to FnF shareholders and have shaken the trust of investors in FnF and capital markets.

HERA is copy of a banking laws that applies to FDIC. FDIC is a insurance corporation besides a banking regulator. FDIC provides explicit insurance coverage on bank deposit accounts to protect banks from bank runs. So FDIC has legitimate business interests to act in its own interest as a insurance corporation but not as a banking regulator.

FnF are mono-line insurance companies and have nothing to do with banking and are not vulnerable to bank runs. FHFA is only a regulator and not a insurance corporation. FHFA does not provide any insurance or guarantees on FnF deposits. So naturally FHFA can not claim any legitimate business interests to act in its own interest and impound FnF capital assets.

Using banking laws (HERA) for "targeted" regulation of non-banking private shareholder companies (FnF) to circumvent well established legal framework (risk based capital requirements for mono-line insurance companies, conservatorship process etc ) and, to impair FnF and harm the FnF shareholders (using SPS/NWS and perpetual conservatorship) violates the most basic legal principles and most basic constitutional principles.

This aberration is glaringly clear with more than 13 years of apaquely and secretly run FHFA conservatorship with no accountability to anyone and completely impaired conservatees that were very well capitalized and in good financial health at the time of start of conservatorship.

After more than 13 years of tortuous FnF conservatorship, it must convince all that there are no better alternatives than to evolving FnF business models. All along it has been the political/Gov decisions that are the root cause of all the actual and made up FnF problems.

More than 13 years of unaccountable and harmful FHFA conservatorship has made it impossible now, for FnF to raise any new core capital from the markets. The first step to rehabilitating FnF as private shareholder companies is to end FHFA conservatorship and let FnF build their capital in whatever best possible manner without onerous FHFA mandates. FnF have paid back more than their original SPS obligations to Gov. It is time for FHFA to release FnF free from unreasonable SPS obligations. Gov has the obligations to support FnF in building up their capital after all the harm FHFA conservatorship has done to them.

Shareholders request FHFA to end this repugnant Conservatorship and return FnF to lawful owners without any further delay.