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Alfred M Pollard
Title
Professorial Lecturer
Department
MCDONOUGH SCHOOL OF BUSINESS
General profile Research Publications Syllabi General profile
Phone202-414-3788
Emailpollaram@georgetown.edu
Alt. emailalfredpollard@hotmail.com
LocationG-04 Old North
BioAlfred Pollard serves as General Counsel for the Federal Housing Finance Agency, the safety and soundness regulator for Fannie Mae and Freddie Mac and the twelve federal Home Loan Banks.

Previously he has served on the staffs of two United States Senators, was a Senior Vice President for Government Affairs for the fifth largest U.S. bank, ran two trade association government relations departments for congressional and regulatory matters.

Pollard is author of a two volume text on banking law, a number of journal articles and frequently has testified before Congress and spoken on national media.

Alfred Pollard holds a BA in International Affairs and a JD from the University of North Carolina— Chapel Hill and a PhD in Foreign Affairs from the University of Virginia. He serves as adjunct faculty at the University of Virginia School of Law.
EducationPhD (1980) University of Virginia, Government- Foreign Affairs
JD (1974) UNC-Chapel Hill, Law
BA (1971) UNC-Chapel Hill, Government— Latin American Affairs
LanguagesFrench (speak, read)
Spanish (speak, read, write)

KATHLEEN M. MURPHY
PRESIDENT & CEO
August 4, 2009
Alfred M. Pollard, Esq.
General Counsel
Maryland Bankers Association
Federal Housing Finance Agency
Fourth Floor
1700 G Street, N.W.
Washington, D.C. 20552
Attention: Comments/RlN 2590-AA12
Re: Proposed Rule on Executive Compensation
Dear Mr. Pollard:
As the President and CEO ofthe Maryland Bankers Association, I am writing on behalf
of our members to comment on the Federal Housing Finance Agency’s (”FHFA”)
proposed rule on Executive Compensation published on June 5, 2009 (the “Proposal”).
The Proposal’contains regulations on executive compensation that would implement
sections 1113 and 1117 of the Housing and Economic Recovery Act of2008 (”HERA”)
with respect to the Federal Home Loan Banks (FHLBanks).
Founded in 1896, the Maryland Bankers Association (MBA) was created to make
Maryland banks stronger and more successful. MBA’s members are FDIC-insured banks
of all sizes and charter types, with more than 1,800 branches operating in Maryland and
holding nearly 90 percent ofthe $96 billion in deposits in the state. We appreciate this
opportunity to comment.
On behalf of our members, I am concerned that the Proposal fails to take into account the
unique cooperative ownership structure at the FHLBanks and its impact on FHLBank
executive compensation. I am also concerned that the Proposal would, in effect,
substitute an FHF A determined formula for setting executive compensation (by
apparently specifying p31iicular institutions - the Federal Reserve Banks and the Farm
Credit Banks - as comparator institutions and by establishing a presumptive median
compensation level cap) at each ofthe FHLBanks for the discretion ofthe independent
boards of directors ofthe FHLBanks who are elected by the member/owners
(shareholders) ofthe FHLBanks.
The members ofthe Maryland Bankers Association who are shareholders/members ofthe
FHLBanks are very familiar with the methods and processes for determining
compensation. We believe that the FHLBanks already have in place a robust and
186 DUKE OF GLOUCESTER STREET’ ANNAPOLIS, MARYLAND 21401
(443) 837-1601 • (800) 327-5977’ FAX (410) 269-1874’ E-mail: kmurphy@mdbankers.com·Web Site: www.mdbankers.com

GSE 2010-2011 Goals Comment Letter
April 12, 2010
Page 3 of 3
production platforms that can originate loans cost-effectively. Fannie Mae has made an effort
to develop an origination process using lenders to originate the loans, while Freddie Mac has
relied upon structured transactions with banks. Both approaches have expanded liquidity, but
both have fallen short of the intended goal of making long-term mortgage finance available to
the owner or developer of smaller properties, especially in secondary markets and rural areas.
The major contributors to this gap between expectations and performance are: the origination
network; the risk profile for the loan servicer; the cost to originate the loans; and the return on
the loan to the capital source.
We further encourage FHFA to provide incentives for the government to work with the GSEs to
jointly share risk to develop a program that is cost-effective for rate and fees and with limited
recourse to this market segment. This would allow for greater effort by the GSEs to develop the
needed origination in a more cost-effective way and to develop more direct relationships with
regional and local banks and others that have the network to originate the loans.
Commercial Mortgage-Backed Securities (CMBS)
The use of CMBS purchases to meet affordable housing goals has been debated as long as the
Enterprises have engaged in such activities. Their participation in the market has expanded
liquidity to the apartment sector and, therefore, we support their purchase of CMBS for
multifamily properties or CMBS that include a significant percentage of multifamily mortgages.
The credit for affordable housing goals should be commensurate with the risk taken in the
investment, as purchasing an AA- to AAA- rated security does not present the same level of risk
as guaranteeing the purchase of a mortgage. There is subordination protection to the
purchaser and the cost of special servicing activities is not borne out directly by the bond holder.
The incentives for capturing affordable housing goals should be weighed against the level of risk
associated with the purchase. We recommend that a reduced percentage of units be allocated
to such investment activities.
FHFA Actions to Support Affordable Housing Production Goals
FHFA can enhance the ability of Fannie Mae and Freddie Mac to meet the affordable rental
housing needs of low- and moderate-income families by extending permission for the two firms
to serve as liquidity providers for tax-exempt variable-rate multifamily mortgage bonds. As
investors come to the market, it would be prudent to increase the ability of Fannie Mae and
Freddie Mac to provide credit enhancement on these bond instruments, thereby providing
needed mortgage financing. FHFA should work with the firms to develop a reasonable market
response to providing liquidity.
We also encourage FHFA to call for HUD and the Enterprises to look at how their risk-sharing
activities can be implemented in a way that would benefit both HUD and the Enterprises in
improving market liquidity. HUD has become hamstrung by its limited capacity, while the
Enterprises have demonstrated their capability to purchase mortgages in the volumes needed to
support the market.
We appreciate the opportunity to comment. Should you need further information or have any
questions, please contact David Cardwell, NMHC Vice President of Capital Markets and
Technology at (202) 974-2336 or dcardwell@nmhc.org.
Sincerely yours,
Douglas M. Bibby Douglas S. Culkin, CAE
President President
National Multi Housing Council National Apartment Association

June 15, 2010

On Today's Program

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Etheridge offers pathetic apology

Congressman Bob Etheridge (D-NC) was caught on tape physically assaulting some students who asked him if he agreed with Obama's policies. A commenter had this great campaign ad suggestion for Etheridge's next opponent: “Any citizen can ask me my position at any time, and I will answer directly and honestly rather than committing assault and battery. If Rep. Etheridge wants to know who I am, I am Renee Ellmers, and I approve this message.” Glenn reacts to the apology on radio today. ( Transcript, Insider Audio)

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The 4th Hour: Is it a good idea to let your 16-year old daughter sail the world solo? Pat and Stu debate it in this FREE CLIP. Insider Extreme Members can enjoy the full 4th hour on demand.

Tonight on TV: Glenn talks to the out of the box thinking minds who are dreaming up every possible scenario the U.S. could potentially face, tonight at 5pm only on the Fox News Channel!

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