GSEs, Federal Credit and Federal Finance

Building on his understanding of the home mortgage market and federal loan and loan guarantee programs, Mr. Stanton has provided counsel to federal credit agencies and to congressional committees and others seeking to enhance the safety and soundness of government-sponsored enterprises.

Operations of the Home Mortgage Market

Comments on the Proposed Rulemaking by the Federal Housing Finance Agency (FHFA) on the “Enterprise Regulatory Capital Framework,” August 28, 2020

“Designation of Fannie Mae and Freddie Mac as SIFIs,” letters to the Financial Stability Oversight Council, March 31, 2014, and November 27, 2017, by Alex J Pollock and Thomas H. Stanton

“What Comes Next After Fannie Mae and Freddie Mac?” Public Administration Review, November/December 2013

Comment on FHFA Release, “Building a New Infrastructure for the Secondary Mortgage Market,” 2012

“The Government Corporation as a Promising Organizational Form to Deliver Government Support to the Mortgage Market,” 2012

“To Fix the GSEs, Copy Ginnie Mae’s Model,” American Banker, March 10, 2011

“Fannie Mae and Freddie Mac: How can we Improve Support of the Mortgage Market?” Report to the Kirwan Institute for the Study of Race and Ethnicity, the Ohio State University, report, 2009, published as chapter 12 in Christy Rogers and John A. Powell, Where Credit is Due: Bringing Equity to Credit and Housing after the Market Meltdown, 2013.

“The Failure of Fannie Mae and Freddie Mac,” Journal of Law and Policy, vol. 18, no. 1, 2009

“Lessons from Public Administration: Recommendations for the Future of Fannie Mae and Freddie Mac and Other Aspects of Government’s Response to the Financial Debacle,”
presentation to the 45th Annual Conference on Bank Structure and Competition, Federal Reserve Bank of Chicago, May 2009

“Government-Sponsored Enterprises: Reality Catches up to Public Administration Theory,” Public Administration Review, July/August, 2009

“Viewpoint: Treat the GSEs Like Other Institutions,” American Banker, July 25, 2008

“Viewpoint: GSE Shareholder Bailout a Bad Idea,” American Banker, April 11, 2008

“The Life Cycle of the Government-Sponsored Enterprise: Lessons for Design and Accountability,” Public Administration Review, September/October 2007

“When Government Isn’t Exactly Government,” Journal of Public Administration Research and Theory, Vol. 14, no. 3, pp. 435-437, July 2004

“A Fannie and Freddie for the 21st Century,” The Wall Street Journal, June 17, 2003

“Government Sponsored Enterprises (GSEs): Why is Effective Government Supervision Hard to Achieve?” presentation to the 37th Annual Conference on Bank Structure and Competition, Federal Reserve Bank of Chicago, May 2001

“Restructuring Fannie Mae and Freddie Mac: Framework and Policy Options,” Studies on Privatizing Fannie Mae and Freddie Mac, US Department of Housing and Urban Development, May 1996.

“Government-Sponsored Enterprises and the Transformation of the American Housing Finance System,” Housing Finance International, September 1995

“Government Sponsored Enterprises and Changing Markets: The Need for an Exit Strategy,” The Financier: Analyses of Capital and Money Market Transactions, May 1995

“History and Evolution of Government Sponsored Enterprises,” prepared for the House Committee on the Budget, December 17, 1992

“Increasing the Accountability of Government-Sponsored Enterprises:  Next Steps,” Public Administration Review, November/December 1991.

“Federal Supervision of Safety and Soundness of Government-Sponsored Enterprises,” The Administrative Law Journal, Summer 1991.

“Increasing the Accountability of Government-Sponsored Enterprises:  First Steps,” Public Administration Review, September/October 1990.

“Budgetary Consequences of Using a Government Sponsored Enterprise to Provide Financial Assistance to the Federal Savings and Loan Insurance Corporation,” Public Budgeting & Finance, Autumn 1989.

“Government Sponsored Enterprises as Federal Instrumentalities: Reconciling Private Management with Public Accountability,” Public Administration Review, July/August 1989 (Co-authored with Ronald C. Moe).

Improving Federal Involvement in the Financial Markets

LECTURES

“Risk, the Financial Crisis, and Enterprise Risk Management,” lecture at the Yale School of Organization and Management, April 12, 2019

Elmer B. Staats Lecture, “Strengthening our Public and Private Institutions: A National Imperative,” National Academy of Public Administration. November 2011

Elliot Richardson Lecture: “The Importance of Legitimacy in the Government’s Response to the Financial Crisis,” American Society for Public Administration and National Academy of Public Administration, March 2009, published in Public Integrity, Volume 12, Number 1 / Winter 2009-10

ARTICLES & CHAPTERS

“The 2008 Financial Crisis Revisited: Risks and Responses,” chapter 4 in The 2008 Financial Crisis Revisited, 2021

“Finance and Philosophy: Why We’re Always Surprised, by Alex J. Pollock 2019,” book review, Banking & Finance Law Review, April 2019

“Regulating (From) the Inside: the Legal Framework for Internal Control in Banks and Financial Institutions,” book review, Banking and Finance Law Review, August 2017

“Bank Supervision — Unfinished Business from the Financial Crisis,” Banking & Financial Services Policy Report, December 2014

“Administering Dodd-Frank: Unfinished Business from the Financial Crisis,” Public Administration Review, November/December 2014

“Constructive Dialogue and ERM: Lessons from the Financial Crisis,” chapter 32 of John R. Fraser, Betty J. Simkins, and Kristina Narvaez, Implementing Enterprise Risk Management:  Case Studies and Best Practices, (John Wiley & Co., 2014)

“Listening to Regulators Can Keep Your Bank Out of Trouble,” American Banker, August 20, 2012

“Creating a Financial System Safety Board,” The American Interest, Autumn September/October) 2009

“Strengthening Government’s Ability to Deal with the Financial Crisis,” IBM Center for the Business of Government, 2009

“Lessons from Public Administration: Recommendations for the Future of Fannie Mae and Freddie Mac and Other Aspects of Government’s Response to the Financial Debacle,”
presentation to the 45th Annual Conference on Bank Structure and Competition, Federal Reserve Bank of Chicago, May 2009

“Reducing Government Involvement in a Market: Lessons from the Privatization of Sallie Mae,” Public Budgeting & Finance, Spring 2008

– Recipient of the Jesse Burkhead Award for Best Article in Public Budgeting & Finance, 2008
see also slide presentation (pdf)

“Institutional Factors Related to Investing Social Security Funds in Equity Securities,” The Financier: Analyses of Capital and Money Market Transactions, November 1997

“Commentary: Liquidity and Competition in Rural Credit Markets,” Financing Rural America, Federal Reserve Bank of Kansas City, April 1997

“Nonquantifiable Risks and Financial Institutions,” in Global Risk Based Capital Regulations, edited by Professors Charles Stone and Anne Zissu, (Irwin Professional, 1994).

Strengthening Federal Credit Programs

“Response to Office of Management and Budget: Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government, Financial Assistance,” July 2021

“Help Borrowers, Don’t Hurt Them: Federal Credit Programs Need to Focus on Outcomes, not Volume,” Public Administration Review, November/December 2017

“Federal Credit Programs: Borrower Outcomes Matter More than Volume,” with Alan B. Rhinesmith and Michael E. Easterly, May 2017

“Managing Information and Risk: Promising Practices of Federal Financial Programs,” sponsored by Deloitte & Touche USA, May 2006

Federal Credit Programs: Managing Risk in the Information Age, IBM Center for the Business of Government, April 2005

“Loans and Loan Guarantees,” Chapter 12 in Tools of Government: A Guide to the New Governance, Lester M. Salamon, Editor, Oxford University Press, 2002

Credit Scoring and Loan Scoring: Tools for Improved Management of Federal Credit Programs, PwC Endowment for the Business of Government, July 1999