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         rities offered by Wall Street, its unfamiliarity with the new credit risks, worries that
         the price of the mortgages wouldn’t be worth the risk, and regulatory concerns sur-
         rounding certain products.   At this and other meetings, Lund recommended study-
         ing whether the current market changes were cyclical or more permanent, but he also
         recommended that Fannie “dedicate significant resources to develop capabilities to
         compete in any mortgage environment.”   Citibank executives also made a presenta-
         tion to Fannie’s board in July , warning that Fannie was increasingly at risk of
         being marginalized, and that “stay the course” was not an option. Citibank proposed
         that Fannie expand its guarantee business to cover nontraditional products such as
         Alt-A and subprime mortgages.   Of course, as the second-largest seller of mort-
         gages to Fannie, Citibank would benefit from such a move. Over the next two years,
         Citibank would increase its sales to Fannie by more than a quarter, to  billion in
         the  fiscal year, while more than tripling its sales of interest-only mortgages, to
          billion. 
            Lund told the FCIC that in , the board would adopt his recommendation: for
         the time being, Fannie would “stay the course,” while developing capabilities to com-
         pete with Wall Street in nonprime mortgages.   In fact, however, internal reports
         show that by September , the company had already begun to increase its acquisi-
         tions of riskier loans. By the end of , its Alt-A loans were  billion, up from
          billion in  and  billion in ; its loans without full documentation
         were  billion, up from  billion in ; and its interest-only mortgages were
          billion in , up from  billion in . (Note that these categories can over-
         lap. For example, Alt-A loans may also lack full documentation.) To cover potential
         losses from all of its business activities, Fannie had a total of  billion in capital at
         the end of . “Plans to meet market share targets resulted in strategies to increase
         purchases of higher risk products, creating a conflict between prudent credit risk
         management and corporate business objectives,” the Federal Housing Finance
         Agency (the successor to the Office of Federal Housing Enterprise Oversight) would
         write in September  on the eve of the government takeover of Fannie Mae.
         “Since , Fannie Mae has grown its Alt-A portfolio and other higher risk products
         rapidly without adequate controls in place.” 
            In its financial statements, Fannie Mae’s disclosures about key loan characteristics
         changed over time, making it difficult to discern the company’s exposure to subprime
         and Alt-A mortgages. For example, from  until , the company’s definition of
         a “subprime” loan was one originated by a company or a part of a company that spe-
         cialized in subprime loans. Using that definition, Fannie Mae stated that subprime
         loans accounted for less than  of its business volume during those years even while
         it reported that  of its conventional, single-family loans in ,  and 
         loans were to borrowers with FICO scores less than . 
            Similarly, Freddie had enlarged its portfolios quickly with limited capital.   In
         , CEO Richard Syron fired David Andrukonis, Freddie’s longtime chief risk offi-
         cer. Syron said one of the reasons that Andrukonis was fired was that Andrukonis
         was concerned about relaxing underwriting standards to meet mission goals. He told
         the FCIC, “I had a legitimate difference of opinion on how dangerous it was. Now, as
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