August 24, 2011 Mr. Terence W.

Edwards Executive Vice President, Credit Risk Management Fannie Mae 3900 Wisconsin Avenue, N.W. Washington, DC 20016 terence_w_edwards@fanniemae.com

RE: Interest Charges and Guarantee Fees (G-fees) on Make-whole and Repurchase Requests and Fees Charged by Fannie Mae on Loans Foreclosed Dear Mr. Edwards: MBAs members continue to work to fix the problems that gave rise to the current credit crisis and to work in good faith to implement loss mitigation programs on behalf of investors like Fannie Mae. Recently, the Mortgage Bankers Association 1 (MBA) has heard concerns from its members about a number of Fannie Maes fees and interest charges on repurchase/make-whole requests and fees for delays in the foreclosure process. Our members would like to get a better understanding of these fees. As business partners with Fannie Mae, our members want to make Fannie Mae whole on losses it incurs when a loan is not properly underwritten or otherwise defective. However, the Seller/Servicers expectation is that such fees and interest should reflect Fannie Maes actual costs. The questions and issues fall into the following categories: The rate used on imputed interest charges and the timing for the commencement of that rate for make-whole transactions. The inclusion of the G-fee in the imputed interest charged on repurchases. Previously paid G-fees on loans repurchased or in make-whole transactions.

The Mortgage Bankers Association (MBA) is the national association representing the real estate finance industry, an industry that employs more than 280,000 people in virtually every community in the country. Headquartered in Washington, D.C., the association works to ensure the continued strength of the nations residential and commercial real estate markets; to expand homeownership and extend access to affordable housing to all Americans. MBA promotes fair and ethical lending practices and fosters professional excellence among real estate finance employees through a wide range of educational programs and a variety of publications. Its membership of more than 2,200 companies includes all elements of real estate finance: mortgage companies, mortgage brokers, commercial banks, thrifts, Wall Street conduits, life insurance companies and others in the mortgage lending field. For additional information, visit MBAs Web site: www.mortgagebankers.org. 1717 Rhode Island Ave, NW | Washington, DC 20036 | www.mortgagebankers.org | (202) 557-2700

Interest Charges and Other Fees August 24, 2011 Page 2 Fees charged for delay of foreclosure related to Seller/Servicers good faith efforts to implement loss mitigation programs such as HAMP.

MBA would like to set up a meeting to include several Seller/Servicers, Fannie Mae staff that you designate, and MBA staff to further discuss our members concerns and questions. Please use Jim Gross, Vice President Financial Accounting and Public Policy and Staff Representative to MBAs Financial Management Committee, at (202) 557-2860 or jgross@mortgagebankers.org, or Michael Carrier, Associate Vice President and Staff Representative to MBAs Secondary and Capital Markets Committee, at 202-557-2870 or mcarrier@mortgagebankers.org to assist in coordinating this meeting. Sincerely,

Stephen A. OConnor Senior Vice President, Public Policy and Industry Relations Mortgage Bankers Association

cc:

David Bohley Director of Industry Relations (david_bohley@fanniemae.com)