DeMarco: Should Government Set Standards, Backstop the Market, or Continue to Issue Guarantees?
Edward J. DeMarco, Acting Director of the Federal Housing Finance Agency
(FHFA) told lawmakers on Tuesday that the role of housing finance reform should
be to promote the efficient
provision of credit to finance mortgages
for
single-family and
multifamily housing. Speaking at a hearing of the House Committee on Financial Services DeMarco said that an efficient market
system for providing
mortgage credit to homebuyers should have certain core characteristics: allowing innovation, providing consumer choice, providing
consumer protection, and
facilitating
transparency. At the most fundamental level, the
key question in housing
finance reform is
what,
and how large, should be the role of the
federal government?
DeMarco said that as an
economist he would approach the issue in the context of a potential market
failure which may lead the
private market to produce less of,
or
more of, a particular good than would
be economically optimal.
There are at
least two potential
market failures
in housing finance that may lead
to an under-provision of mortgage credit.
If undue or unnecessary concerns about the
stability and liquidity of mortgage credit prevail in a purely
private market less
credit will
be provided than in the
absence of this type of
uncertainty. The government response could range from establishing standards
and
greater transparency;
providing liquidity or credit
support, or providing a government guarantee to eliminate uncertainty.
A second failure occurs when the benefits of homeownership are
viewed as extending to the broader aspects
of society. In such cases the market will never provide
the optimal number of homeowners so government may seek to increase demand through subsidies or assistance to encourage
or facilitate consumption, i.e. the mortgage interest tax
deduction.
As of the fourth quarter of
2012, there was about
$9.9 trillion in single family
mortgage debt outstanding, 13
percent of which was directly government guaranteed and 52 percent guaranteed
by Fannie Mae and Freddie Mac (the GSEs).
In the third
quarter of 2012
new
single family mortgage originations totaled approximately $510 billion;
18 percent was guaranteed
through direct
government
programs
and, 66 percent through the GSEs. Measured by securities issuance, the
proportion supported
by
the government
is over 90 percent.
DeMarco said that the longstanding
roles of FHA
and VA suggest the government will continue a role in housing
finance, but the relevant
question is how to move from the
massive government support of today to a future market
with a larger private presence; particularly the $5 trillion
GSE portion of the market.
If policymakers
begin
by
defining which borrowers would
have access to FHA and other government mortgage credit
programs then
it should be easier to consider the
government's
role,
if any,
in the remainder of the market.
Considering how to replace the government sponsored enterprise model, in particular developing
an efficient secondary mortgage market that
can
access capital markets to serve the single family market
that is not covered by traditional government credit programs is central to congressional
consideration of ending the conservatorships.
DeMarco sees three options: a
market-oriented approach that
would ensure broad minimum standards; establishing
a Federal
backstop
to provide liquidity when needed,
or developing a government guarantee structure to
ensure credit stability and limit market uncertainty.
A standard-setting approach
would replace some of the
GSEs' standard-setting
and government guarantees with a
regulatory regime or a market utility that
sets standards to provide a degree of
certainty to investors. The focus in such an
approach
could be on setting
standards around
key features
that investors need
to price credit
risk which include standards associated
with underwriting, pooling and servicing, and
disclosures.
Investors would also be responsible for enforcing
their rights under the standard contracts
developed
under this framework.
To establish a
liquid non-government guaranteed market with such standards would seem to
require a greater homogeneity in
borrower characteristics
which, while it would broadly cover the bulk of
the GSEs' business,
might not be available
serve all of their borrowers. Where characteristics do not fit neatly into
the secondary market, we need to find
a way to get
insured depository institutions
back into the business of funding mortgages, a role DeMarco sees the Federal Home
Loan Banks suited to at least partially fill.
It would be
important to consider how
a standard-regulated market
without government guarantees would
operate in a time of stress.
Preserving liquidity and the availability of credit are important functions
and a determination should be made whether a federal backstop such as FHA for
credit or the Treasury Department for liquidity is needed. Or alternatively,
with a more standardized
market and
infrastructure,
would it be possible for an existing guarantor,
like Ginnie Mae, to play
such a temporary guarantee function?
The third option would resemble a housing finance system with
some type of government guarantee as
we have today. A guarantee would
enable securities to be priced favorably and
have a high degree of liquidity to reflect
that guarantee but would not provide the benefit
of pricing the credit risk
of the underlying mortgages. Private sector capital through
equity investment
would stand in a first
loss position, with a
government guarantee that
was funded through an
insurance premium being available to cover other losses.
Replacing the GSEs' implicit guarantee with
an
explicit one does not resolve all
the shortcomings and
inherent conflicts in that model,
and it may produce its
own problems. First,
the presumption behind the need
for
an explicit guarantee is that
the market either
cannot evaluate and price the risk
of mortgage default at a reasonable price or it cannot manage that amount of
mortgage credit risk
on its own. However, is there reason to believe that
the government
will do better? If the
government
backstop is underpriced, taxpayers eventually may foot the
bill again.
Second, if it provides explicit
credit support for the majority of mortgages it would likely want to determine the allocation
or pricing of mortgage credit for particular groups or
geographic areas, distorting risk pricing and risking further taxpayer involvement.
Third, explicit credit
support for most mortgages
in addition to the mortgage interest deduction would further direct our
nations investment
dollars toward housing and possibly drive up
the price of housing, other things being equal.
DeMarco also told committee
members about FHFA's 2013 goals under the 1212 Strategic Plan for the GSEs and about
the proposed reform of the securitization platform. This was a reprise of information DeMarco
sent to the committee on February 21 and covered by MND.
DeMarco concluded his testimony by
saying that few could have imagined in 2008 "That we would
be approaching the fifth
anniversary of placing
Fannie Mae and Freddie Mac in
conservatorships
and have made little
meaningful progress to bring these government
conservatorships to an
end.
He urged Congress to make the
necessary policy determinations
and then set about
ending these conservatorships
and transitioning to a future housing finance system that can
serve our children, grandchildren, and
beyond.