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Letter to Mr. Franklin D. Raines 1 (June 2001)

handle is hein.congrec/cbo9417 and id is 1 raw text is: CONGRESSIONAL BUDGET OFFICE                                                 Dan L. Crippen
U.S. CONGRESS                                                               Director
WASHINGTON, DC 20515
June 21, 2001
Mr. Franklin D. Raines
Chairman and Chief Executive Officer
Fannie Mae
3900 Wisconsin Avenue, NW
Washington, DC 20016
Dear Mr. Raines:
I am writing to respond to your written comments, dated May 9, 2001, on the
Congressional Budget Office's draft study on the housing GSEs and to reply more
generally to some related arguments, including ones in a recent speech by Tim
Howard, Fannie Mae's Benefits to Home Buyers: The Business Perspective.
The first set of comments concerns the calculation of tax and regulatory
benefits that the GSEs receive. You argued that the subsidy is exaggerated when
figured on a pretax basis. CBO routinely does all such calculations before taking
federal taxes into account. Moreover, it is entirely possible that if calculated on an
after-tax basis, the ratio of benefits to Fannie Mae and benefits to homeowners would
increase.
The second set of issues you raise involves the calculation of the debt benefit.
You asserted that the spread between portfolio returns and debt should be 78 basis
points rather than 90 basis points. Ninety basis points, however, is the spread
reported in Fannie Mae's annual report, which is based on mortgages rather than the
GSE's overall portfolio. You also made the point that the total debt in Table 2 of
CBO's report includes debt that is not used exclusively for conforming mortgages but
also for multifamily mortgages and nonmortgage investments, whereas the subsidy
to multifamily borrowers is not included in the pass-through estimates. In fact, we
based the subsidy estimates on the full increase in the amount of debt outstanding and
so included a subsidy to multifamily borrowers. The total subsidy calculation
implicitly includes all subsidies that are passed through.
As to the issue of the appropriate comparison group, I refer you to the study,
which explains in greater detail why CBO used that particular set of firms. We
understand that this comparison could overstate the subsidy calculation but not by
much. Your own consultants produced estimates that are consistent with ours.
Further, many other assumptions that we made are favorable to Fannie Mae and
Freddie Mac.

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