Fannie Mae (FNMA)

[Robert from yahoo bd]

Nice! From the OIG FDIC report:

Ensuring the Validity and Efficacy
of FDIC Rulemaking

On October 19, 2022, the U.S. Court of
Appeals for the Fifth Circuit ruled that the
funding of the Bureau of Consumer
Financial Protection (CFPB) violated the
appropriations clause of the Constitution
and, as a result, the CFPB’s Payday
Lending Rule was invalid.85 The CFPB
receives it funding from the Federal
Reserve, which is funded through bank
assessments. The Court explained that this
funding structure is not subject to the
Congressional appropriations process and
therefore violated the Appropriations Clause. There is a risk that the Fifth
Circuit’s ruling could also be applied to the
FDIC. The FDIC is funded outside of the
Congressional appropriations process
through bank assessments (similar to the
Federal Reserve).

Also, FDIC rulemaking should be a
transparent process that analyzes the need
for bank regulation and the compliance
burden placed on banks. A foundational
component of transparent rulemaking is the
FDIC’s access to reliable information to
measure a regulation’s costs and benefits.

Effective governance is critical to ensure
proper oversight of the FDIC and the
accomplishment of its mission. The FDIC
Board and management should ensure that
the FDIC is identifying and managing risks
through an effective ERM program and
promptly addressing recommendations
made by the OIG and GAO to address
identified risks. The FDIC should measure
program effectiveness by establishing
outcome measurements and also address
whether the FDIC will follow Executive
Branch guidance. The FDIC should ensure
the validity of its rulemaking and ensure that
rules are premised on solid cost benefit
analyses.

https://www.fdicoig.gov/reports-publications/top-management-and-performance-challenges/2022-top-management-and-performance