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Peter J. Wallison                    503


         Freddie were major buyers of NTMs well before Wall Street fi rms and the subprime
         lenders who came to dominate the business entered the subprime PMBS market
         in any signifi cant way. Moreover, the GSEs did not (indeed, could not) appreciably
         increase their purchases of NTMs during the years 2005 and 2006, when they
         had lost market share to the real PMBS issuers, Countrywide and other subprime
         lenders.
              Th  e following discussion addresses each of the claims about the GSEs’
         motives in turn, and in the end will show that the only plausible motive for their
         actions was their eff ort to comply with HUD’s AH goals.

         Did the GSEs acquire NTMs to “compete for market share” with
         Wall Street or others?
              Th  e idea that Fannie and Freddie were newcomers to the purchase of NTMs
         between 2004 and 2007, and reduced their underwriting standards so they could
         compete for market share with Wall Street or others, is wrong. As shown in Table 7,
         the GSEs’ acquisition of subprime loans and other NTMs began in the 1990s, when
         they fi rst became subject to the AH goals. Research shows that, in contravention
         of their earlier standards, the GSEs began to acquire high loan-to-value (LTV)
         mortgages in 1994, shortly aft er the enactment of the GSE Act and the imposition
         of the AH goals, and by 2001—before the PMBS market reached $100 billion in
         annual issuances—the GSEs had already acquired at least $700 billion in NTMs,
                                              104
         including over $400 billion in subprime loans.  Far from following Wall Street or
         anyone else into subprime loans between 2004 and 2007, the GSEs had become the
         largest buyers of subprime and other NTMs many years before the PMBS market
         began to develop. Given these facts, it would be more accurate to say that Wall Street
         and the subprime lenders who later came to dominate the PMBS market followed
         the GSEs into subprime lending. Table 7 does not show any signifi cant increase in
         the GSEs’ acquisition of NTMs from 2004 to 2007, and the amount of subprime
         PMBS they acquired during this period actually decreased. Th  is is consistent with
         the fact—outlined below—that the GSEs did not make any special eff ort to compete
         for market share during these years.




















         104   Pinto, “Government Housing Policies in the Lead-up to the Financial Crisis: A Forensic Study,” Chart
         52, p.148, http://www.aei.org/docLib/Government-Housing-Policies-Financial-Crisis-Pinto-102110.pdf.
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