"Legal Reasons Write a Write-Down is Hard" - First thing I notice is that the Mortgage Bankers Association should have coherent slide titles.
The +$200 billion accounted for on the federal balance sheet as a claim
This isn't hard. The amount shows up out of the blue - $1 for every $1 in retained earnings from a private company. It is not coming from taxes or any appropriation method that was accounted for in "spendable" money. It comes from thin air, it can be removed back to thin air.
Under standard federal accounting, this would be treated as a cost to the federal government, and would increase the federal deficit in the fiscal year in which the write-down occurs
Uhhh.... Yet nobody seems to mind the decrease in federal deficit when money appears from thin air as stolen company assets? Hypocrites!
Congress may need to weigh in on deficit impact (PAYGO)
Wrong. From Tax Policy Center dot org: PAYGO, which stands for “pay as you go,” is a budget rule requiring that tax cuts and mandatory spending increases must be offset (i.e., “paid for”) by tax increases or cuts in mandatory spending. PAYGO has never applied to discretionary spending (spending that is controlled through the appropriations process), but this spending has at times between subject to its own ceilings.
So no, there is no Congressional input needed. The SPS liquidation preference has nothing to do with tax cuts nor mandatory spending increases.
May exceed HERA authority
So HERA allows the FHFA to do whatever it wants to private citizens, but not if it impacts an OMB budget? Nonsense. Newsflash -> it already impacts the OMB budget by putting the stolen assets on the balance sheet. The authority can't work in only one direction.