Public Comment AC96 Risk Based Capital Guidelines FannieMae

March 26, 2007 Ms. Jennifer J. Johnson, Secretary Office of the Comptroller of the Currency Board of Governors 250 E Street, S.W. Federal Reserve System Mail Stop 1-5 20th Street and Constitution Avenue, N.W. Washington, DC 20219 Washington, D.C. 20551 Re: Docket Numbers R-1261 and R-1238 Re: Docket Numbers 06-09 and 06-15 Mr. Robert E. Feldman, Executive Regulation Comments Secretary Chief Counsel’s Office Attention: Comments Office of Thrift Supervision Federal Deposit Insurance Corporation 1700 G Street, N.W. 550 17th Street, N.W. Washington, DC 20552 Washington, DC 20429 Re: RIN 3064-AC73 and RIN 3064-AC96 Attention: Nos. 2006-33 and 2006-49 Dear Sir or Madam: Fannie Mae welcomes this opportunity to comment on the Basel IA and Basel II Notices of Proposed Rulemaking (NPR). We typically do not comment on rules proposed by the banking agencies. However, in the current instance, the agencies specifically request comment, particularly in the Basel IA NPR, on the risk weights to be assigned to our securities: “Question 5: The Agencies are considering whether to use financial strength ratings to determine risk weights for exposures to GSEs, where this type of rating is available, and are seeking comment on how a financial strength rating might be 1applied.” We confine our comment letter to a discussion of this issue. 1 71 Fed. Reg. 77446, 77454 (December 26, 2006) Executive ...