If the JB Admin want to take over the GSEs by an Admin action they will need to settle the lawsuits first? Otherwise an Admin action will be stalled by Constitutional challenges - wouldn't you expect a MQD lawsuit now challenging the LLPA fee structure because it favors borrowers with poor credit scores at the expense of borrowers who have worked hard to maintain a high credit score? If the JB Admin proposes some type of Admin action to make up for the failings of the CRA and to promote DEI objectives there will be MQD challenges which will be added to the existing Separation of Powers challenges.
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