Howardonmortgagefinance.com Website Review

Capital Requirements” on June 12. After the comment period closed on November 16, there were 77 entries on FHFA’s comment log. Half (38) were from individuals who wrote short comments ranging from one sentence to a few paragraphs expressing their personal points of view, and there were eight administrative-type entries (correspondence to and information or meeting summaries from FHFA). The remaining 31 entries broke out this way: One each from Fannie and Freddie; 5 from private individuals—Myself, the team of Ed Golding, Laurie Goodman and Jun Zhu (who work at the Urban Institute but submitted their piece as individuals), and Andrew Davidson (who submitted three separate comments); 1 from an affordable housing advocate—The Center for Responsible Lending; 3 from private mortgage insurance entities—Genworth, Arch Capital, and U.S. Mortgage Insurers; 4 from Wall Street interests—Moelis & Company, Pershing Square Capital Management, Katz Capital, and The Structured Finance Industry Group; 5 from community lending groups— The Independent Community Bankers of America, The Community Home Lenders As*ociation, The Credit Union National As*ociation, The National As*ociation of Federally-Insured Credit Unions, and Heartland Credit Union As*ociation; 4 from large trade as*ociations—The American Bankers As*ociation, The Mortgage Bankers As*ociation, The National As*ociation of Realtors, and The National As*ociation of Homebuilders; three from Washington think tanks—The American Enterprise Institute, The Housing Policy Council, and The American Action Forum), and four from multifamily interests—The DUS Advisory Council, Walker and Dunlop, NorthMarq Capital, and the National Multifamily Housing Council and National Apartment As*ociation, commenting jointly. For those whose interest is in multifamily lending I must offer an apology: from the start of the capital exercise I have concentrated almost exclusively on the single-family side, since that is where my expertise (and most of the controversy) lies. But multifamily lenders