Proposed Changes to Methodology for Stand...

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U.S. PUBLIC FINANCE MARCH 19, 2012 Table of Contents: OVERVIEW OF HOUSING BONDS WITH CREDIT ENHANCED MORTGAGES 2 PROPOSED CHANGES TO METHODOLOGY 4 1. Cap at Aa1 the rating for new transactions secured by MBS or CEI with semi-annual debt service payments and downgrade to Aa1 from Aaa existing transactions. 4 2. Add new cash flow stress test for single family transactions 5 3. Change the way in which we assign a rating of a housing transaction that utilizes an acquisition fund GIC 5 4. More conservatively incorporate the risk of low investment rates 5 APPENDIX 1: TRANSACTIONS THAT MAY BE AFFECTED BY METHODOLOGY CHANGE 7 Bond Issue 7 MOODY’S RELATED RESEARCH 26 Analyst Contacts: NEW YORK 1.212.553.1653 Gregory W. Lipitz 1.212.553.7782 Vice President-Senior Analyst [email protected] Florence Zeman 1.212.553.4836 Associate Managing Director [email protected] Naomi Richman 1.212.553.0014 Managing Director-Public Finance [email protected] Proposed Changes to Methodology for Stand- Alone US Public Finance Housing Transactions with Mortgage Enhancements This request for comment describes proposed changes to Moody’s rating methodology for rating stand-alone US Public Finance housing transactions secured by mortgages that are fully guaranteed or insured by a third party such as the U.S. government, a government sponsored entity (GSE) such as Fannie Mae and Freddie Mac, or a state entity. These changes reflect the performance of these transactions in recent years during an environment of high defaults on underlying mortgages, record-low interest rates, and frequent financial institution downgrades. The proposed changes will be incorporated into a methodology report that will consolidate approximately eleven existing methodologies and rating implementation guidelines. 1 The proposed changes are: 1. Cap at Aa1 the ratings of stand-alone housing transactions with semi-annual debt service payments secured by Ginnie Mae/Fannie Mae/Freddie Mac mortgage-backed securities (MBS) or Fannie Mae/Freddie Mac stand-by Credit Enhancement Instruments (CEI). This could result in the downgrade of up to 453 existing Aaa-rated transactions to Aa1 following publication of the methodology. 2. Add a cash flow test for single family housing transactions to reflect the risk of immediate prepayments of MBS principal. 3. For transactions that use a guaranteed investment contract (GIC) during the acquisition/construction phase (acquisition fund GIC), cap the bond rating at the rating of the acquisition fund GIC provider during the acquisition/construction phase. Once this phase is complete, the bonds would be evaluated in accordance with our broader methodology which gives less weight to the investment provider’s rating, and ratings could potentially be upgraded. 2 4. Assign more conservative rating levels to transactions that do not have GICs and rely on market investment earnings. 1 See Moody’s Related Research for the list of publications. 2 Our current methodology is reflected in our publication, Methodology Update: Ratings that Rely on Guaranteed Investment Contracts , dated December, 2008.

Transcript of Proposed Changes to Methodology for Stand...

REQUEST FOR COMMENT

U.S. PUBLIC FINANCE MARCH 19, 2012

Table of Contents:

OVERVIEW OF HOUSING BONDS WITH CREDIT ENHANCED MORTGAGES 2 PROPOSED CHANGES TO METHODOLOGY 4

1. Cap at Aa1 the rating for new transactions secured by MBS or CEI with semi-annual debt service payments and downgrade to Aa1 from Aaa existing transactions. 4

2. Add new cash flow stress test for single family transactions 5

3. Change the way in which we assign a rating of a housing transaction that utilizes an acquisition fund GIC 5

4. More conservatively incorporate the risk of low investment rates 5

APPENDIX 1: TRANSACTIONS THAT MAY BE AFFECTED BY METHODOLOGY CHANGE 7

Bond Issue 7 MOODY’S RELATED RESEARCH 26

Analyst Contacts:

NEW YORK 1.212.553.1653

Gregory W. Lipitz 1.212.553.7782 Vice President-Senior Analyst [email protected]

Florence Zeman 1.212.553.4836 Associate Managing Director [email protected]

Naomi Richman 1.212.553.0014 Managing Director-Public Finance [email protected]

Proposed Changes to Methodology for Stand-Alone US Public Finance Housing Transactions with Mortgage Enhancements

This request for comment describes proposed changes to Moody’s rating methodology for rating stand-alone US Public Finance housing transactions secured by mortgages that are fully guaranteed or insured by a third party such as the U.S. government, a government sponsored entity (GSE) such as Fannie Mae and Freddie Mac, or a state entity. These changes reflect the performance of these transactions in recent years during an environment of high defaults on underlying mortgages, record-low interest rates, and frequent financial institution downgrades. The proposed changes will be incorporated into a methodology report that will consolidate approximately eleven existing methodologies and rating implementation guidelines.1

The proposed changes are:

1. Cap at Aa1 the ratings of stand-alone housing transactions with semi-annual debt service payments secured by Ginnie Mae/Fannie Mae/Freddie Mac mortgage-backed securities (MBS) or Fannie Mae/Freddie Mac stand-by Credit Enhancement Instruments (CEI). This could result in the downgrade of up to 453 existing Aaa-rated transactions to Aa1 following publication of the methodology.

2. Add a cash flow test for single family housing transactions to reflect the risk of immediate prepayments of MBS principal.

3. For transactions that use a guaranteed investment contract (GIC) during the acquisition/construction phase (acquisition fund GIC), cap the bond rating at the rating of the acquisition fund GIC provider during the acquisition/construction phase. Once this phase is complete, the bonds would be evaluated in accordance with our broader methodology which gives less weight to the investment provider’s rating, and ratings could potentially be upgraded.2

4. Assign more conservative rating levels to transactions that do not have GICs and rely on market investment earnings.

1 See Moody’s Related Research for the list of publications. 2 Our current methodology is reflected in our publication, Methodology Update: Ratings that Rely on Guaranteed Investment Contracts, dated December, 2008.

U.S. PUBLIC FINANCE

2 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

We invite market participants to provide feedback to this proposal by sending comments by April 20, 2012 to [email protected]. We will consider comments received by that date and would expect to publish an updated methodology shortly thereafter.

Figure 1 summarizes the specific proposed changes to the existing methodologies.

FIGURE 1

Summary of Proposed Methodology Changes

Current Methodology Proposed Methodology

1) Rating levels for stand-alone housing transactions with semi-annual payments secured by Ginnie/Fannie/Freddie MBS or Fannie/Freddie Mac Stand-by Credit Enhancement Instruments

Transactions are eligible for Aaa rating

Cap at Aa1 all future transactions and downgrade outstanding transactions to Aa1

2) Additional prepayment cash flow scenario in single-family housing transactions

0% PSA, 100% PSA and 3-year average life prepayment speeds3

Current scenarios plus a scenario that shows an immediate prepayment of outstanding MBS

3) Deals with acquisition fund GICs Transactions can receive a Aaa rating if the GIC provider’s rating is at least A1/P-1

Rating will be capped at the same level as the GIC provider’s rating during construction/acquisition phase

4) Transactions that do not rely on GICs

Bond rating is linked to the date of any debt service or parity shortfall, assuming 0% reinvestment earnings

Assigns more conservative rating levels incorporating date of projected debt service or parity shortfall (see chart, section 4) and other factors

Overview of Housing Bonds with Credit Enhanced Mortgages

Housing bonds which are secured by mortgages guaranteed by the US government or a Government Sponsored Enterprise (GSE) such as Fannie Mae or Freddie Mac, are a source of financing for individual homeowners and developers of “multifamily” projects such as hospitals, nursing homes, assisted living facilities and rental units. The bonds are issued by municipalities and local and state housing finance agencies and usually sold as tax-exempt securities.

Whether they are secured by a single credit-enhanced multifamily mortgage or pool of single family mortgages, the underlying structure of the secured housing credits is the same. In each, the borrower(s) makes monthly mortgage payments to a loan servicer. After subtracting its servicing fee and any applicable guaranty fee from the monthly mortgage payments, the servicer forwards the net monthly payments to the bond trustee. The trustee then collects and invests these payments in accordance with the transaction documents. These funds are used, along with any investment earnings and after taking out fees and other expenses, to pay bondholders.

3 We may also ask for other cash flow scenarios, like split-rate prepayment speeds, when appropriate.

U.S. PUBLIC FINANCE

3 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

FIGURE 1

Overview of Single Family MBS Deal

Overview of Multifamily Deal

U.S. PUBLIC FINANCE

4 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

Our methodology applies to the following types of mortgage enhancements:

1. Ginnie Mae, Fannie Mae or Freddie Mac MBS

2. Fannie Mae or Freddie Mac Standby Credit Enhancement Instrument (CEI)

3. Federal Housing Administration (FHA) mortgage insurance

4. State of New York Mortgage Agency’s Project Pool Insurance (SONYMA)

Proposed changes to methodology

1. Cap at Aa1 the rating for new transactions secured by MBS or CEI with semi-annual debt service payments and downgrade to Aa1 from Aaa existing transactions.

We are proposing to cap at Aa1 the rating of certain stand-alone housing transactions, resulting in the downgrade of existing transactions with these structures to Aa1 from Aaa. This change applies only to transactions with semi-annual debt service payments and to transactions in which the enhancement on the loans are Ginnie Mae MBS or Fannie Mae or Freddie Mac MBS or CEIs. This rating action could affect up to 453 transactions4

Notwithstanding the strong credit quality of MBS or mortgage insurer counterparties, we believe that because of the weak performance of some of these transactions due to trustee or servicer error, the Aa1 rating more appropriately reflects the observed probability of third party mistakes and loss given default. We have observed credits that have had their financial position impaired because a third party failed to adhere to the requirements of the trust indenture or financing agreement

. Bonds secured by loans insured by FHA or SONYMA and MBS or CEI transactions which are monthly pay pass-throughs will not be affected by this methodology change and will continue to be rated in accordance with our existing methodology.

5

Our general approach for rating these transactions reflects a combination of the underlying credit quality of the mortgage guarantor, the structure of the guarantee, the bond legal structures and our analysis of bond cash flow projections under various stresses. While the sufficiency of the mortgage payments is reflected in the rating assigned to enhancement provider on the loan, the payment of bond principal and interest is not guaranteed by that entity. As a result, the rating we assign to these bonds is also dependent on the strength of the legal and financial structures as well as the performance of all the parties to adhere to the legal documents. Given that the performance of third parties is a material element in these structures, a rating of Aaa does not appropriately reflect the risk of non-performance to bondholders.

, resulting in steep rating downgrades when errors come to light. Examples of these mistakes include failure to properly redeem bonds with excess revenue, redeem bonds correctly with prepayments of mortgage principal, pay fees correctly and properly invest funds used to pay debt service. Importantly, these transactions do not always have an external support or asset management to mitigate against potential losses caused by third party actions.

4 Please see Appendix 1 for a list of deals that may be affected. 5 Please see Moody’s publication, “Failure to Adhere to Legal Documents May Result in Rating Downgrades for Local Housing Transactions,” dated October, 2010 and

other publications listed in the Related Research section of this publication

U.S. PUBLIC FINANCE

5 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

2. Add new cash flow stress test for single family transactions

For new and existing stand alone single family transactions, we are proposing to add an additional cash flow analysis that will test the worst-case scenario for mortgage prepayments6

3. Change the way in which we assign a rating of a housing transaction that utilizes an acquisition fund GIC

. In this scenario all of the mortgages prepay at the same time at the lowest parity level. During the housing crisis, some Moody’s rated bonds experienced prepayment speeds in excess of our most rapid prepayment stress scenario, which assumes that the mortgages will have an average life of three years. With this additional scenario, we will test a transaction’s ability to withstand the most severe prepayment scenario – an immediate prepayment. In determining the rating of a transaction, in addition to this scenario, we will assess the probability of an immediate prepayment by looking at, among other things, the housing market and economy in the geographic area of the mortgages and the amount and number of mortgages in each MBS pool.

In determining the maximum rating level of a bond that is supported by a GIC, our current methodology makes no distinction between GICs that are used during the construction of a project/acquisition of mortgages phase of a bond transaction (acquisition fund GICs) or those used for the deposit of float funds (float fund GICs). Under our current methodology, a GIC provider with a rating of at least A1/P-1 can support a bond rating of up to and including Aaa7

We are proposing to treat acquisition fund GICs and float fund GICs differently. For transactions that use an acquisition fund GIC we will rate the bonds no higher than the rating of the GIC provider during construction or the acquisition of MBS. When the construction/acquisition period is over, we would review the bonds again using the broader methodology. For float fund GICs, we will continue to follow our published guidelines.

.

An acquisition fund GIC has more impact on the credit quality of a series of bonds than a float fund GIC. During the construction phase or the period during which the Trustee is directed to purchase MBS, the full amount of bond proceeds are often invested in an acquisition fund GIC, exposing bondholders to the risk of losing the entire amount of bond proceeds if the GIC provider unexpectedly goes bankrupt during this time. Float fund GICs, however, are generally no longer than six months and expose bondholders to a much smaller amount of lost principal and/or interest if the GIC provider goes bankrupt.

4. More conservatively incorporate the risk of low investment rates

In 2009, as a result of unprecedented low interest rates, we changed our interest rate assumptions for housing transactions that rely on investment earnings to 0%. As a result of this change, we downgraded the ratings of those transactions that exhibited either debt service or parity shortfalls in the future as a result of the transaction’s inability to generate enough investment income at a 0% investment rate. Transactions that demonstrated debt service or parity shortfalls within 15 years were downgraded to levels between Aa to Ba depending on when the shortfall occurred. Our expectation at that time was that the then current period of low interest rates would be temporary and that we would start to see rates rising within two years. The rating we assigned reflected our estimate of the probability of default given a stressful interest rate environment that we expected to ameliorate.

6 This test would not apply to open, parity indentures. 7 If the GIC provider’s rating is downgraded, we downgrade the bond rating in accordance with our published guidance (Methodology Update: Ratings that Rely on

Guaranteed Investment Contracts, dated December, 2008). If the GIC provider rating falls below A3, the rating of the bonds will equal the provider’s rating.

U.S. PUBLIC FINANCE

6 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

Recently, the Federal Reserve announced a policy of maintaining rates at current levels at least until 2014. We believe that as a result of this policy, many transactions with projected default dates assuming low interest rates in the mid- to long-term have a greater risk of actual default, as they would need higher interest rates to ensure cash flow sufficiency.

We are proposing to refine when the rating will change on a bond that is not supported by a GIC as follows:

Date of Cash Flow Insufficiency or Parity Below 100%

Maximum Rating Level Current Methodology Recommendation

Aaa >=15 Years >=18 Years

Aa >=10 and <15 Years >=13 Years and <18 Years

A >=5 and <10 Years >=8 and <13 Years

Baa >=3 and <5 Years >=6 and <8 Years

Ba or lower <3 Years <6 Years

We are also proposing to incorporate other factors into the rating, such as the breakeven rate that the program needs to avoid shortfalls and the probability that interest rates will rise to those levels In making this determination, we will rely on forward interest rate curves and other information that will inform our opinion regarding the likelihood that the deal will not experience stress from low interest rates.

U.S. PUBLIC FINANCE

7 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

Appendix 1: Transactions That May Be Affected By Methodology Change

Bond Issue

» ABAG Finance Authority for Nonprofit Corporations Multi-Family Housing Revenue Bonds (Park Manor Apartments Project) 2001 Series A

» Alabama HFA Multi-Family Housing Revenue Refunding Bonds (GNMA Collateralized - Green Valley Project) 1995 Series A & B

» Albany (City of) NY, Industrial Development. Auth. Civic Facility Revenue Bonds (GNMA Collateralized Mortgage Loan - Daughters of Sarah Nursing Home Company, Inc. Project) 2002A

» Allegheny County Residential Finance Authority Multi-Family Mortgage Revenue Bonds 2011 Series YY

» Allegheny County Residential Finance Authority Multi-Family Mortgage Revenue Bonds 2011 Series ZZ

» Allegheny County Residential Finance Authority PA, Multi-Family Mortgage Revenue Bonds, 1998 Series CC-1, CC-2, DD-1, DD-2

» Allegheny County Residential Finance Authority PA, Multi-Family Mortgage Revenue Bonds, 2001 Series JJ-1, JJ-2 & KK-1, KK-2

» Allegheny County Residential Finance Authority PA, Multi-Family Mortgage Revenue Bonds, 2002 Series LL & MM

» Allegheny County Residential Finance Authority PA, Multi-Family Mortgage Revenue Bonds, 2004 Series NN & OO & PP

» Allegheny County Residential Finance Authority PA, Multi-Family Mortgage Revenue Bonds, 2005 Series QQ, RR, SS

» Allegheny County Residential Finance Authority PA, Multi-Family Mortgage Revenue Bonds, 2006 Series TT

» Allegheny County Residential Finance Authority PA, Multi-Family Mortgage Revenue Bonds, 2007 Series UU & VV

» Allegheny County Residential Finance Authority, PA Multi-Family Housing Revenue Bonds, Series of 2009 (Metowers Apartments Project)

» Allegheny County Residential Finance Authority, PA Series 2010 XX (Non-AMT) Multi-Family Mortgage Revenue Bonds

» Anderson (County of) TN, Health & Educational Facility Multi-Family Housing Revenue Refunding Bonds (Clinton Towers Project) 2003

» Arizona HFA Multi-Family (GNMA Collateralized - Casa De Flores Project) 2007

» Asheville Housing Authority, NC Multi-Family Housing Revenue Bonds (GNMA Collateralized - Battery Park Project) 2004

» Atlanta Urban Residential Finance Authority, GA, Multi-Family Housing Revenue Bonds (GNMA Collateralized - Amal Heights Townhomes Project), Series 2010, $9.125MM

» Bethany Retirement Home, Inc., NY Multi-Family Revenue Bonds (GNMA Coll. Mortgage Loan - Bethany Retirement Home, Inc. Project.) 2007

» Bexar County Housing Finance Corporation, TX Multi-Family Housing Revenue Bonds (GNMA Collateralized - Wurzbach Manor Apartments Project) 2003

» Bexar County Housing Finance Corporation, TX Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Perrin Square Apartments) 2001

» Bexar County Housing Finance Corporation, TX Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Stablewood Farms Apartments) 2001

U.S. PUBLIC FINANCE

8 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Bexar County Housing Finance Corporation, TX Multi-Family Housing Revenue Bonds (Park Ridge Apartments Project) Series 2004

» Broward County Housing Finance Auth., FL, Mortgage Revenue Bonds Series 1991-D

» Brown (County of) OH Mortgage Revenue Bonds (GNMA Collateralized - Hyde Park West/Forest Glade Apartments Projects) Series 2003A & B

» Butler (County of) OH Multi-Family (GNMA Collateralized - Trinity Manor) 2006

» Butler County Industrial Dev. Auth., PA Health Care Facilities Revenue Bonds (GNMA Collateralized - St. John Lutheran Care Center Project) 2001A

» CA Statewide Community Dev Auth Multi-Family Housing Rev (GNMA Col -Springdale Apts) Ser.'99

» Calcasieu Parish Public Trust Authority Single Family Housing Series 2003A/B

» Calcasieu Parish Public Trust Authority, LA, Multi-Family Mortgage Revenue Bonds (Guaranteed Mortgage-Backed Securities Program

» California Housing Finance Agency Affordable Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - One Santa Fe Apartments) 2009 Series 1-19 and 2011 Issue A

» California Housing Finance Agency, Affordable Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Wolf House Apartments Project), Series 2009 A-20, $16.500MM

» California Housing Finance Agency, Affordable Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan – Jackson Hills Apartments) 2009 Series A-15

» California Housing Finance Agency, Affordable Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan – LA Pro I Apartments) 2009 Series A-8

» California Rural Home Mortgage Authority Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) Series 2002D

» California Statewide Community Dev Auth Multi-Family Housing rev Bonds (GNMA Collateralized-Steinbeck Commons) Ser.'98L & LT

» California Statewide Communities Development. Auth. FHA Insured GNMA Collateralized (Sunnyside/Vermont Project) 2001A and A-T

» California Statewide Communities Development. Auth. Multi-Family Housing Revenue Bonds (GNMA Collateralized - Lincoln Apartments Project) 2001

» California Statewide Communities Development Authority Multi-Family Housing Revenue Bonds (Silver Ridge Apartments) 2000 Series H

» Cameron County Housing Finance Corporation, Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Rockwell Manor Apartments Project), 2007

» Canadian County Home Finance Authority and Cleveland County Home Loan Authority - Mortgage Backed Securities Program, Multi-Family Mortgage Revenue Bonds Series 2000A (Non-AMT), Series 2000B (AMT), Series 2000C (Taxable)

» Capital Area Housing Finance Corporation, TX Multi-Family Mortgage Revenue Bonds (GNMA and Fannie Mae Mortgage-Backed Securities Program) 2002

» Charlotte City Housing Authority, NC, Multi-Family Housing Revenue Bonds (Ginnie Mae Collateralized Mortgage Loan - South Oak Crossing Apartments Project) Series 2006

U.S. PUBLIC FINANCE

9 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Chicago (City of) IL Collateralized Multi-Family Mortgage Revenue Bonds 2001A & B

» Chicago (City of) IL Collateralized Multi-Family Mortgage Revenue Bonds 2001C

» Chicago (City of) IL Collateralized Multi-Family Mortgage Revenue Bonds 2002B

» Chicago (City of) IL Collateralized Multi-Family Mortgage Revenue Bonds 2002C

» Chicago (City of) IL Collateralized Multi-Family Mortgage Revenue Bonds 2002D

» Chicago (City of) IL Collateralized Multi-Family Mortgage Revenue Bonds 2006A&B

» Chicago (City of) IL Single Family-MBS2002A

» Chicago (City of) IL, Collateralized Multi-Family Mortgage Revenue Bonds, 2006 E&F

» Chicago (City of) IL, Collateralized Multi-Family Mortgage Revenue Bonds, 2006 G&H

» Chicago (City of) IL, Collateralized Multi-Family Mortgage Revenue Bonds, 2006 I & J

» Chicago (City of) IL, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2006C&D

» Chicago (City of) IL, Housing Revenue Refunding Bonds, 2006K

» Chicago (City of) IL, Multi-Family Housing Revenue Bonds (Drexel Preservation Project), 2007

» Chicago (City of) IL, Multifamily Housing Revenue Bonds (Hazel Winthrop Apartments) Series 2012A

» Chicago Multi-family Housing Rev Ser 1999A (GNMA Col-Hearts United Apts Project)

» City of Albuquerque, New Mexico, Industrial Development Revenue Refunding Bonds (GNMA Collateralized-Albuquerque Manor Nursing Home Project) Series 1999 A&B

» City of Cambridge, Ohio, Multi-Family Housing Revenue Bonds (Ginnie Mae Collateralized - Cambridge Heights Apartments Project) Series 2008

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007 A

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007 C

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007 E

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007 G

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007-2A

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007-2C

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007-2E

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007-2G

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007-2I

» City of Chicago, Collateralized Multi-Family Mortgage Revenue Bonds, Series 2007-2K

» City of Chicago, Multi-Family Housing Revenue Bonds (Clara's Village Project), Series 2007A (FHA Insured/GNMA)

» City of Chicago, Multi-Family Housing Revenue Bonds (Coppin House Project), Series 2007A (FHA Insured/GNMA)

» City of Chicago, Multi-Family Housing Revenue Bonds (Sankofa House Project), Series 2007A (FHA Insured/GNMA)

U.S. PUBLIC FINANCE

10 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» City of Coon Rapids, Minnesota, Multi-Family Rental Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Mississippi View Apartments Project) Series 2006

» City of Elkhart, Indiana, Multi-Family Housing Mortgage Revenue Refunding Bonds (GNMA Collateralized - Prairie Village Apartments Project) Series 1998A & B

» City of Golden Valley, MN Senior Living Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Calvary Center Apts. Project) Series 2006A

» City of Greeley, Colorado, Multi-Family Housing Revenue Bonds (GNMA Collateralized - Meeker Commons) Series 2000

» City of Indianapolis Indiana Multi-Family Housing Mortgage Revenue Bonds, GNMA Collateralized Cloverleaf Phase I Apartments Project dated 12/1/00

» City of Kansas City, City of Olathe and LaBette County, Kansas, GNMA Collateralized Mortgage Revenue Bonds, Series 1992

» City of Kansas City, Kansas, GNMA Collateralized Mortgage Obligation, Series 1995

» City of Lebanon, Indiana Multi-Family Housing Mortgage Revenue Bonds GNMA Collateralized-Lebanon Manor Village Apartments Series 2002A

» City of Minneapolis Minnesota Multi-Family Housing Refunding Bonds GNMA Collateralized Mortgage Loan East Bank Village Apartments Series 2001

» City of Minneapolis Minnesota Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan-Seward Towers Project) Series 2003

» City of Minneapolis Minnesota Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Sumner Field Phase Ii, Lp Project) Series 2003A

» City of Minneapolis Minnesota Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan Sumner Field Partners Lp Project) Series 2002A

» City of Newark (New Jersey) 2001 Healthcare Facility Revenue Bonds (GNMA Collateralized - New Community Urban Renewal Corporation Extended Care Facility) Series A

» City of Pine City, MN, Health Care and Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - North Branch Senior Living, LLC Project) Series 2006A

» City of Shelbyville Indiana Multi-Family Housing Mortgage Revenue (GNMA Collateralized Blueridge Terrace Apartments Project dated 12/1/00

» City of St. Paul Multi-Family Housing Refunding Revenue Bonds Series 1999A & 1999B (Wellington Project)

» Clay County Housing Finance Authority, FL, Multi-Family Mortgage Revenue Bonds (Multi-County Program), 2007 A-1 & A-2

» Cobb County Housing Authority, GA, Multi-Family Housing Revenue Bonds, (Garrison Plantation Development Project) Series 1994, $11.180MM

» Columbus Metropolitan Housing Authority, OH Multi-Family Housing Mortgage Revenue Bonds (GNMA Collateralized - New Village Homes Project) 2002A

» Columbus Regional Airport Authority, OH Multi-Family Housing Mortgage Revenue Bonds (Berwick Grove Project) 2004

» Columbus Regional Airport Authority, OH Multi-Family Housing Revenue Bonds (GNMA Collateralized - Educator Apartments Project) 2004A & 2004B

U.S. PUBLIC FINANCE

11 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Columbus Regional Airport Authority, OH Multi-Family Housing Revenue Bonds (GNMA Collateralized - Joseph Knight Towers and William Presser Towers Projects) 2004A & B

» Columbus Regional Airport Authority, OH Multi-Family Housing Revenue Bonds (GNMA Collateralized - Partnership Equities, Inc. Projects) 2003A and 2003B

» Community Development Administration Maryland Department of Housing and Community Development Multi-Family Development Revenue Bonds (Park Montgomery) Series 2000C

» Community Development Administration Multi-Family Revenue Bonds(Edgewater Village) Series 2000B-1

» Community Development Administration Multi-Family Revenue Bonds(Edgewater Village) Series 2000B-2

» Community Development Administration, Maryland Department of Housing and Community Development, Multi-Family Development Revenue Bonds (Washington Gardens) Series 2005B

» Community Development Administration, Maryland Department of Housing and Community Development, Multi-Family Development Revenue Bonds (Waters Towers Senior Apartments Project) Series 2001F

» County of Butler, Ohio, Multi-Family Housing Revenue Bonds (Meadow Ridge Apartments Project) Series 2002A

» County of Clermont, Ohio, Mortgage Revenue Bonds, Series 1993 (FHA Insured Mtd. Loan - S.E.M. Villa II Project)

» County of Cuyahoga, Ohio, Multi-Family Housing Mortgage Revenue Bonds, 2001 Series A (GNMA Collateralized - Longwood Phase One Associates, L.P. Project)

» County of Franklin Ohio Multi-Family Housing Mortgage Revenue Bonds GNMA Collateralized Carriage House Apartments Series 2002

» County of Franklin, Ohio, Mortgage Revenue Refunding Bonds, Series 1998E (GNMA Collateralized Gateway Apt. Homes Project)

» County of Lorain, Ohio - Multi-Family Housing Revenue Bonds, Series 2009A (GNMA Collateralized – Kensington Square Apartments Project)

» County of Westchester Industrial Development Agency, Civic Facility Revenue Bonds, Series 2001A (GNMA Collateralized Mortgage Loan - Living Independently for the Elderly, Inc. Project)

» CRHMFA Homebuyers Fund, CA, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006A

» CRHMFA Homebuyers Fund, CA, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2007A

» CRHMFA Homebuyers Fund, CA, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2007E

» CRHMFA Homebuyers Fund, CA, Single Family Housing Bonds (South Plains Project) 2007 C

» CRHMFA Homebuyers Single Family Mtg.(Mortgage-Backed Securities Program) Single family Mortgage Revenue (Mortgage-Backed Security Program) 1993 issue A, Series 1, 2 & 3

» Cuyahoga (County of) OH Multi-Family Housing Revenue Bonds (GNMA Collateralized - Clifton Plaza Apartments Project) 2005

» Cuyahoga (County of) OH Multi-Family Housing Mortgage Revenue Bonds (GNMA Collateralized - Arbor Park Phase Two Associates Project) 2003A

» Cuyahoga (County of) OH Multi-Family Housing Mortgage Revenue Bonds (GNMA Collateralized - Arbor Park Phase Three Associates, LP Project) 2004A

U.S. PUBLIC FINANCE

12 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Cuyahoga (County of) OH Multi-Family Housing Mortgage Revenue Bonds (GNMA Collateralized - Carter Manor Apartments) 2004

» Cuyahoga (County of) OH Multi-Family Housing Mortgage Revenue Bonds (GNMA Collateralized - Rainbow Terrace Apartments Project) 2001A

» Cuyahoga (County of) OH Multi-Family Housing Revenue Bonds (GNMA Collateralized - Allerton Apartments Project) 2007A

» Cuyahoga (County of) OH, Senior Housing Mortgage Revenue Bonds (GNMA Collateralized - R.H. Myers Apartments Project), 2007

» D.C HFA - (Bowling Green Apts Project)Multi-Family Housing Revenue Bonds (Bowling Green Apartments Project) GNMA Collateralized Series 2003

» D.C HFA - Savannah Heights Apartments Project Multi-Family Housing Revenue Bonds (Savannah Heights Apartments Project), GNMA Collateralized Series 2004

» D.C HFA Multi-Family Housing Revenue Refunding Bonds (Garfield Hills Apartments), Series 2006

» D.C HFA, Multi-Family Housing Revenue Bonds (Shipley Park Apartments Project), Series 2005, $11.920Mm

» D.C HFA, Multi-Family Housing Revenue Bonds, Georgia Commons Project), GNMA Collateralized Series 2009, $16.695Mm

» D.C. HFA - Multi-Family Program Fund 2001 GNMA (Jeffrey Gardens Project.)Multi-Family Housing Revenue Bonds, (Jeffrey Gardens Project) GNMA Collateralized Series 2001

» D.C. HFA - Multi-Family Program Fund 2001Ab GNMA (Columbia Heights Village Project.)Multi-Family Housing Revenue Bonds, (Columbia Heights Village Apartments Project) GNMA Collateralized Series 2001A & B

» Dakota County Community Development Agency, Minnesota, Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Ebeneezer Ridges Assisted Living Project) Series 2000

» Dakota County Community Development Agency., MN Multi-Family Housing Revenue Bonds (GNMA Collateralized - Mortgage Loan - Grande Market Place Project) 2002A & A-T

» Dakota County Community Development Agency., MN Multi-Family Housing Revenue Bonds (GNMA Collateralized - Rose Apartments) 2001

» Dallas Housing Finance Corporation, Tax Multi-family Housing Revenue Series '98 (Claremont Apts.)

» Dallas Housing Finance Corporation, Tax Multi-family Housing Revenue Series '98 (Towne Ctr. Apartment.)

» DeSoto Housing Finance Corp Multi-Family Housing Rev Ref (Mt. Vernon Apts) Ser 1998A

» El Paso (County of), CO, GNMA Collateralized Mortgage Revenue Bonds (Stetson Meadows Apartments Project) 2002A & 2002A-T

» El Paso (County of), CO, Single Family Mortgage Revenue Refunding Bonds, Series 1992A Class B-2

» Erie (County of) OH Multi-Family Housing Revenue Bonds (GNMA Collateralized - Harbourview Senior Housing Project) 2007

» Erie County Industrial Development Agency, NY, Multi-Family Housing Revenue Bonds (GNMA Collateralized - Elmwood Square Apartments) Series 2004

» Erie County Industrial Development Agency, NY, Multi-Family Housing Revenue Bonds (Sutton Place Apartments) Series 2003

U.S. PUBLIC FINANCE

13 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Escambia County Housing Finance Auth., FL, Multi-Family Mortgage Revenue Bonds (Multi-County Program), Series 2007A

» Escambia County Housing Finance Auth., FL, Multi-Family Mortgage Revenue Bonds, 2007B

» Escambia County Housing Finance Authority Multi-Family Mortgage Revenue Bonds Series 2004A

» Escambia County Housing Finance Authority Multi-Family Mortgage Revenue Bonds Series 2006A

» Escambia County Housing Finance Authority, FL Series GSE-R Multi-Family Mortgage Revenue Bonds

» Essex County Improvement Authority, NJ Multi-Family Housing Revenue Bonds (Ballantyne House Project) 2002

» Essex County Improvement Authority, NJ Multi-Family Housing Revenue Bonds (Mount Carmel Towers Project) 2002

» Florida HFA Housing Revenue (Vizcaya Villas Project) Series '96M

» Florida HFA Housing Revenue Bonds, 1999 Series (Deer Meadow Apartments)

» Florida HFA Multi-Family Housing Revenue Bonds, Series 1999 (Hampton Court Apartments)

» Florida HFC - Multi-Family Mortgage Revenue Bonds (U.S. Treasury/Government-Sponsored Enterprises New Issue Bonds Program) )(New Horizons Apartments) Series 2010C (Non-AMT)

» Florida Housing Finance Corporation Multi-Family Mortgage Revenue Bonds (Grande Court at Boggy Creek Apartments) Series 2002

» Florida Housing Finance Corporation, Multi-Family Mortgage Revenue Bonds (U.S. Treasury/GSE NIBP) Series 2009G (NON-AMT) (The Landings at Timberleaf Apartments)

» Fort Bend County Housing Finance Corp., TX Multi-Family Mortgage Revenue Bonds (GNMA and Fannie Mae Mortgage-Backed Securities Program) 2002

» Fort Worth Housing Finance Corporation GNMA Collateralized Multi-Family Housing Revenue Bonds(Villas of Eastwood Terrace Senior Apartments)Series 2002

» Franklin (County of) OH Multi-Family (GNMA Collateralized - Agler Green Project) 2002A

» Franklin (County of) OH Multi-Family Housing Revenue Bonds (GNMA Collateralized - Waggoner Senior Housing Project) Series 2002A

» Fredericksburg (City of) VA, Ind. Dev. Auth. Multi-Family Housing Revenue Bonds (GNMA Mortgage-Backed Securities Program - Heritage Park I Apartments Project) 2003A

» Fredericksburg (City of) VA, Ind. Dev. Auth. Multi-Family Housing Revenue Bonds (GNMA Mortgage-Backed Securities Program - Heritage Park II Apartments Project) 2003B

» Gateway Public Facility Corporation, TX Multi-Family Housing Revenue Bonds (Stonegate Villas Apartments) 2004

» Greencastle Housing, Inc. Mortgage Revenue ref. ser. '93A & B (FHA ins. mtge. loan-Castlebury Apts. Sect. 8 Assist. Project.) (FNMA coll.)

» Hampton Redevelopment and Housing Authority Multi-Family Housing Revenue Bonds (Tidewater Seniors Apts Project), Series 2001

» Harris County Housing Finance Corporation, TX Multi-Family (GNMA Collateralized Palomino Place Apts) 2001

» Harris County Housing Finance Corporation, TX Multi-Family Housing Revenue Bonds (Kimberly Pointe Apartments) 2003

U.S. PUBLIC FINANCE

14 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Harrisonburg Redevelopment & Housing Auth, VA Taxable Multi-Family Housing Revenue Bonds (Huntington Village Apartments Project) 2001B

» Herkimer (County of) NY, I.D.A. Civic Facility Revenue Bonds (GNMA Collateralized - Folts Adult Home Project) 2005 A & B

» Hillsborough Co. Housing Finance Auth., FL, Single Family Housing Revenue Bonds (Multi-County Program), Series 2006

» Hillsborough Co. Housing Finance Auth., FL, Single Family Housing Revenue Bonds, 2007

» Hillsborough County Housing Finance Authority, FL Series 2009A Multi-Family Mortgage Revenue Bonds

» Hospital for Special Surgery, NY, GNMA Collateralized Taxable Revenue Bonds (Hospital for Special Surgery Project), Series 2011, $64.965MM

» Housing & Redevelopment Authority of the City of St. Paul and Minneapolis MN Multi-Family Housing Revenue Bonds Series 2006A (GNMA Collateralized Mortgage Loan - Torre de San Miguel Homes, Westminster Place & Vista Village Projects)

» Housing & Redevelopment Authority of the City of St. Paul MN Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Phalen Senior Lofts) Series 2005

» Housing & Redevelopment Authority of the City of St. Paul MN Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - University & Dale Project) Series 2005A

» Housing and Redevelopment Authority of the City of St. Paul MN Multi-Family, Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Lyons Court Project) Series 2004

» Housing Authority of the City of Athens Georgia Multi-Family Mortgage Revenue Bonds (GNMA & Fame Mortgage Backed Securities Program) Series 98 A

» Housing Authority of the City of Durham Multi-Family Housing Revenue Bonds(Oakley Square Apartments), Series 2002 A

» Housing Authority of the City of Milwaukee Multi-Family Housing Revenue Refunding Bonds, Series 2002 (Veterans Housing Projects)

» Housing Authority of the City of Oshkosh, Wisconsin, GNMA Collateral Multi-Family Housing Revenue Bonds, Series 1997 (VNA Apartments Inc. Project)

» Housing Authority of the City of Oshkosh, Wisconsin, GNMA Collateral Multi-Family Housing Revenue Bonds, Series 1997 (VNA Assisted Living Inc. Project)

» Housing Authority of the County of Sacramento Taxable Multi-Family Housing Revenue Bond (The Verandas Apartments) 2000 Issue H-T and Issue H

» Housing Authority of the County of San Bernardino, Multi-Family Mortgage Revenue Bonds (GNMA Collateralized - Pacific Palms Mobilhome Park Project) Series 2001A

» Housing Finance Authority of Broward County, Florida, Multi-Family Mortgage Revenue Bonds, Series 2000

» Housing Finance Authority of Broward County, Florida, Multi-Family Mortgage Revenue Bonds, Series 2007E

» Housing Finance Authority of Lee County Florida Multi-Family Mortgage Revenue Bonds (Multi-County Program) Series 1999A-1 and A-2

» Housing Finance Authority of Lee County Florida Multi-Family Mortgage Revenue Bonds (Multi-County Program) Series 2003

» Housing Finance Authority of Miami-Dade County (Florida), Home Ownership Mortgage Revenue Bonds, Series 2006A

U.S. PUBLIC FINANCE

15 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Houston Housing Finance Corporation, TX Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - North Forest Trails Apartments) 2003

» Houston Housing Finance Corporation, TX Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - RRG Houston Apartments Project) 2001 & 2001-T

» Houston Housing Finance Corporation, TX Single Family Mortgage Revenue Refunding Bonds (GNMA and Fannie Mae Mortgage-Backed Securities Program) 2005A

» Houston Housing Finance Corporation, TX Single Family-MBS2002A & B

» Howard (County of) MD, Multi-Family Housing Revenue Bonds (Patuxent Square Apartments Projects) 2006

» Idaho Housing and Finance Association, Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Wedgewood Terrace Project) Series 2002 A-1 & A-2

» Illinois Development Finance Auth Rev Bonds (GNMA Collateralized - Greek American Nursing Home), Ser 2000A & B

» Illinois Health Facilities Authority Revenue Bonds (GNMA Collateralized - Midwest Care Center I, Inc) 2001

» Illinois Housing Development Authority, Multi-Family Housing Revenue Bonds (Universal City Apts.), Series 2004A

» Indianapolis (City of ), IN Multi-Family Housing Revenue Bonds, Series 1999 (Camby Crossing Apts)

» Indianapolis (City of) IN, Multi-Family Housing Revenue Bonds, (Cambridge Station Apartments Project), Series 2004, $7.8M

» Industrial Development Authority of Arlington County, Virginia, Multi-Family Housing Refunding Revenue Bonds (Arna Valley View Apartments Project) Series 2002

» Jacksonville Housing Finance Authority, FL Multi-Family Housing Mortgage Revenue Bonds (Timuquana Park Apartments) 2004

» Jacksonville Housing Finance Authority, FL Series 2009B HOMEOWNER REVENUE BONDS

» Jacksonville Housing Finance Authority, FL, Homeowner Mortgage Revenue Bonds, 2006A

» Jefferson (County of) CO, Housing Authority Multi-Family Housing Revenue Bonds (Ginnie Mae Collateralized Mortgage Loan - Starcrest Apartments Project) 2001 & 2001-T

» Jefferson (County of,) KY, Multi-Family Housing Revenue Bonds(GNMA Collateralized - Station House Square Apartments), Series 2002A&B

» Jefferson (Parish of) LA, Home Mtge. Auth. Single Family Mortgage Revenue Refunding Bonds 2005

» Jefferson Parish Finance Authority, LA Single Family Mortgage Revenue Refunding Bonds 2007C

» Jefferson Parish Finance Authority, LA, Multi-Family Mortgage Revenue Bonds 2006D

» Jefferson Parish Finance Authority, LA, Multi-Family Mortgage Revenue Bonds 2007B

» Jefferson Parish Finance Authority, LA, Single Family Mortgage Refunding Bonds 2006C

» Jefferson Parish Finance Authority, LA, Single Family Mortgage Revenue Refunding Bonds 2006B

» Kansas City Industrial Development Authority, MO, Housing Facilities Revenue Bonds, (GNMA Collateralized-Grand Boulevard Lofts Project), Series 2009A, $8.875MM

» Kentucky Housing Corporation-Village Manor Project Conduit Multi-Family Housing Revenue Bonds, Series 2005 (GNMA Collateralized - Village Manor Project)

» King Co. Housing. Auth. Nonprofit Housing. Revenue (GNMA Mtge. Backed Sec. - Fred Lind Manor) Ser. '97

U.S. PUBLIC FINANCE

16 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» King County Housing Authority, WA Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Vashon Community Care Center Project) 2001A & B

» Lee County Housing Finance Authority, FL, Multi-Family Mortgage Revenue Bonds 2006

» Lee County Housing Finance Authority, FL, Multi-Family Mortgage Revenue Bonds 2006C, D & E

» Lee County Housing Finance Authority, FL, Multi-Family Mortgage Revenue Bonds, 2007 A, B & C

» Louisiana Housing Finance Agency, Tax-Exempted Assisted Living Facilities GNMA Collateralized Revenue Refunding Bonds, Series 2004A and Series 2004B (AZALEA ESTATES)

» Louisiana Loc Government Envir Facility & Community Dev Auth Mortgage Revenue Bonds (GNMA Collateralized - Cypress Apartments Project) 2003A & B

» Louisiana Loc Government Envir Facility & Community Dev Auth Multi-Family (GNMA Collateralized - Sharlo Apts) 2002

» Louisiana Public Facilities Authority, Mortgage Revenue Bonds (GNMA Collateralized Mortgage Loan - North Park Apartments Project), Series 2005

» Lubbock Housing Finance Corporation (The), TX, Multi-Family Mortgage Revenue Bonds (Guaranteed Mortgage-Backed Securities , 2008

» Macon (City of), GA Housing Authority Multi-Family Mortgage Revenue Bonds, Series 1998A & B

» Macon Housing Auth Single Family Mort Rev Bonds, Ser 2000A & B

» Macon Housing. Auth. Single family mtge. Revenue (GNMA & FNMA Mtge. Backed Sec. Program.), Ser 1995

» Maine Health & Higher Educational Facilities Authority, GNMA Collateralized Mortgage Revenue Bonds Series 2002 (Mid Coast Geriatrics Corporation Project)

» Manatee County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds 2003, Sub Series One

» Manatee County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds 2004, Sub Series One

» Manatee County Housing Finance Authority, FL Single Family Mortgage Revenue Refunding Bonds 2002, Sub-Ser 3 & 4

» Manatee County Housing Finance Authority, FL Single Family-MBS2002, subseries 1 & 2

» Manatee County Housing Finance Authority, FL, Multi-Family Mortgage Revenue Bonds, 2006 Subseries 1

» Maricopa County Industrial Dev. Auth., AZ, Senior Living Healthcare Revenue Refunding Bonds (GNMA Collateralized Mortgage Loan - Immanuel Campus Care Project), 2006 A

» Maricopa County Industrial Dev. Auth., AZ, Senior Living Revenue Bonds (GNMA Coll. Mortgage Loan-Guadalupe Huerta Apartments Project) 2007

» Maricopa County Industrial Dev. Auth., AZ, Senior Living Revenue Bonds (GNMA Coll. Mortgage Loan-Rosa Linda Apartments Project.) 2007

» Maryland Community Development Admin. Multi-Family Development Revenue Bonds (Orchard Mews Apartments Project) 2002C

» Maryland Community Development Admin. Multi-Family Development Revenue Bonds (Princess Ann Townhouses Project) 2001D

» Mason City Health Care Facility Rev Ref (GNMA Collateralized- MCV Health Care Facility Project) Ser 1998

» Memphis Health Educational & Housing Facility Board, TN, Multi-Family Mortgage Revenue Bonds (Edgewater Terrace Apartments Project0, Series 2002A & B

U.S. PUBLIC FINANCE

17 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Miami-Dade County Housing Finance Auth, FL Multi-Family Mortgage Revenue Bonds 2004A

» Miami-Dade County Housing Finance Auth, FL, Home Ownership Mortgage Revenue Bonds, Series 2007A (AMT)

» Miami-Dade County Housing Finance Auth, FL, Homeownership Mortgage Revenue Bonds, 2006 B-1 & B-2

» Miami-Dade County Housing Finance Auth, FL, Multi-Family Mortgage Revenue Bonds 2005A

» Michigan State Housing Development Authority Limited Obligation Multi-Family Housing Revenue Bonds(GNMA Collateralized Program - Deaconess Tower Apartments),Series 2006

» Michigan State Housing Development Authority Limited Obligation Multi-Family Housing Revenue Bonds(GNMA Collateralized Program – Eastside Village Apartments), Series 2004

» Michigan State Housing Development Authority Limited Obligation Multi-Family Housing Revenue Bonds(GNMA Collateralized Program - Huntley Villas Apartments), Series 2002A & B

» Michigan State Housing Development Authority Limited Obligation Multi-Family Housing Revenue Bonds(GNMA Collateralized Program - Martin Luther King Homes Ii),Series 2003A

» Michigan State Housing Development Authority Limited Obligation Multi-Family Housing Revenue Bonds(GNMA Collateralized Program-Burkeshire Pointe Apartments), Series 2002A

» Michigan State Housing Development Authority Limited Obligation Multi-Family Housing Revenue Bonds(GNMA Collateralized Program—Weston Apartments),Series 2005A

» Michigan State Housing Development Authority, Limited Obligation Multi-Family Housing Revenue (GNMA Collateralized Program-Cranbrook Manor) Series 2001A and 2001B

» Michigan State Housing Development Authority, Limited Obligation Multi-Family Housing Revenue Bonds (GNMA Collateralized Program - River Towers Apartments) Series 2004A

» Michigan State Housing Development Authority, Limited Obligation Multi-Family Housing Revenue Bonds, Series 2005A (GNMA Collateralized Program- Hillsdale Gardens Apartments)

» Michigan State Housing Development Authority, Limited Obligation Multi-Family Housing Revenue Bonds, Series 2005A (GNMA Collateralized Program-Center Line Park Towers Apts.)

» Michigan State Housing Development Authority, Limited Obligation Multi-Family Housing Revenue Bonds, Series 2007 (GNMA Collateralized Program- Williams Pavilion Apts.)

» Michigan Strategic Fund Limited Obligation Nursing Home Revenue Refunding Bonds (GNMA Mortgage-Backed Security - Autumn Woods Project) 2002

» Middletown Housing Authority, NY, Multi-Family Housing Revenue Bonds (Summitfield & Moore Heights Apartments Project) Series 2006

» Minneapolis (City of) MN Multi-Family Housing Revenue Bonds (GNMA Collateralized - East Phillips Commons Project) 2003

» Minneapolis (City of) MN Multi-Family (GNMA Collateralized - Bottineau Commons) 2002

» Minneapolis (City of) MN Multi-Family Housing Revenue Bonds (GNMA Collateralized - Bottineau Lofts) 2002

» Minneapolis (City of) MN Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Shingle Creek Commons Project) 2001

» Minneapolis (City of) MN Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan Vantage Flats Project) 2007A

U.S. PUBLIC FINANCE

18 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Minnetonka Multi-Family Housing Rev Refunding (GNMA Collateralized-Archer Heights Apts) Ser '99A

» Minnetonka Multi-Family Housing Rev Refunding (GNMA Collateralized-Cedar Hills Ease & West) Ser '99A&AT

» Modesto (City of) CA Multi-Family Housing Revenue Bonds (Shadowbrook Apartments) 2001B

» Monroe County Industrial Development Agency, NY, GNMA Collateralized Industrial Development Revenue Bonds (Affinity Orchard Place, LP Project) Series 2004

» Montefiore Medical Center, NY (GNMA Collateralized Taxable Bonds) Series 2011

» Montgomery (County of) OH Health Care Project Revenue Bonds (GNMA Collateralized - Mary Scott Nursing Home, Inc. Project) 2001A

» Montgomery (County of) OH Multi-Family Housing Revenue Bonds (Bella Vista Homes Project) 2003A

» Montgomery County Housing Fin Corp, TX Multi-Family Housing Revenue Bonds (Bellshire Apartments Project) 2001

» Moreno Valley Public Financing Authority, Assisted Living Housing Revenue Bonds (GNMA Collateralized - CDC Assisted Living Project) Series 2000A

» Multi Family Housing Revenue Bonds, Series 2006A (GNMA Collateralized - Hillwood II Project)

» Multi-Family Housing Revenue Bonds, Series 2009I-3 (New Issue Bond Program/Ginnie Mae Collateralized – Elim Manor Apartments Project)

» Multi-Family Housing Revenue Bonds, Series 2009I-4 (New Issue Bond Program/Ginnie Mae Collateralized – Westway Gardens Apartments Project)

» Nevada Housing Division - Cedar Village Multi-Unit Housing Revenue Bonds (Cedar Village Apartments) Series 2003

» Nevada Housing Division - Centennial Park Multi Unit Housing Revenue Bonds, 2001 Series A and B (Taxable) (Centennial Park Apartments Project)

» Nevada Housing Division - Community Gardens Multi-Unit Housing Revenue Bonds (Community Gardens Apartments Project) Series 2003

» New Jersey Economic Development Authority GNMA Collateralized Mortgage Revenue Bonds (Victoria Health Corporation Project) 2001A & B

» New Jersey Economic Development Authority Tax-Exempt GNMA Collateralized Mortgage Revenue Bonds (Claremont Health Systems, Inc. Project) 2003A & B

» New Mexico Mortgage Finance Authority Single Family Mortgage Program Bonds 2005A

» New Mexico Mortgage Finance Authority, Single Family Mortgage Program Bonds, 2003 Series A-2 and A-3

» New Mexico Regional Housing. Auth. for Region II Multi-Family Housing Refunding Revenue Bonds (GNMA Collateralized - Country Club Apartments Project)Series 2002

» New Orleans Finance Authority, LA GNMA Mortgage-Backed Securities Revenue Refunding Bonds2003-A- & A-2

» New Orleans Finance Authority, LA Single Family Mortgage Revenue and Refunding Bonds2001A-1, A2 & B-1

» New Orleans Home Mortgage Authority Multi-Family Mortgage Revenue Bonds, Series 1997A, 1997B-1, 1997B-2, 1997C-1

» Newark (City of) Housing Authority Housing Revenue Bonds (GNMA Collateralized-Lock Street Apartments Project), Series 2000A

U.S. PUBLIC FINANCE

19 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Newark (City of) Housing Authority Multi-Family Housing Revenue Bonds (GNMA Collateralized-Fairview Apartments Project), Series 2000A

» Nortex Housing Finance Corporation, Multi-Family Mortgage Revenue Bonds 2006 A

» North Carolina HFA - Special Facility Bonds 2002 Multi-Family Housing Revenue Bonds, Series 2002A (GNMA Collateralized - National Church Residence of Charlotte, NC, Inc. Project)

» North Carolina HFA - Special Facility Bonds 2002 Multi-Family Housing Revenue Bonds, Series 2002B (GNMA Collateralized - National Church Residence of Clinton, NC, Inc. Project)

» North Carolina HFA - Special Facility Bonds 2002 Multi-Family Housing Revenue Bonds, Series 2002C (GNMA Collateralized - National Church Residence of Monroe, NC, Inc. Project)

» North Carolina Housing Finance Agency, Multi-Family Housing Revenue Bonds (GNMA Collateralized - National Church Residence of Rocky Mount, NC, Inc. Project), Series 2002D

» North Little Rock, Arkansas Residential Housing Facilities Board, Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan — Ridgeview Apartments Project), Series 2004

» Nueces County Housing Finance Corporation, TX, Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Gulfway Manor Project) 2007

» Oak Ridge Ind. Dev Bonds Multi-Family Housing Rev Ref Ser.98A&B(GNMA Gardens-South Hill - Woodlands Apts)

» Ohio Capital Corporation for Housing Mortgage Revenue Refunding Bonds (GNMA Collateralized - Chadwick Place Apartments and Plaza Apartments Projects) 2003A & B

» Ohio HFA - (Gama Collateralized- Kennedy Portfolio) Multi-Family Housing Revenue Bonds, Series 2005J (GNMA Collateralized- Kennedy Portfolio Project)

» Ohio Housing Finance Agency, Multi-Family Housing Mortgage Revenue Bonds (GNMA Collateralized —Madonna Homes Project), Series 2006L

» Ohio Housing Finance Agency, Multi-Family Housing Mortgage Revenue Bonds (GNMA Collateralized - Covenant House Apartments Project) Series 2008C

» Oklahoma County Home Finance Authority, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program), Series 2006 A (AMT), $ 20MM

» Oklahoma County Home Finance Authority, OK Single Family Mortgage Revenue and Refunding Bonds (GNMA Mortgage-Backed Securities Program) 2005A-1 and A-2

» Oklahoma County Home Finance Authority, Taxable Residual Revenue Capital Appreciation Bonds, Series 2009, $1.100442MM

» Orange County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds 2004A

» Orange County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds2003B

» Orange County Housing Finance Authority, FL Series 2010 A Homeowner Revenue Bonds

» Orange County Housing Finance Authority, FL, Homeowner Revenue Bonds (Multi-County Program) 2007A

» Orange County Housing Finance Authority, FL, Homeowner Revenue Bonds (Multi-County Program) 2007B

» Orange County Housing Finance Authority, Homeowner Revenue Bonds, 2002 Series B (AMT)

U.S. PUBLIC FINANCE

20 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Orange County Housing Finance Authority, Homeowner Revenue Bonds, 2003 Series A (AMT)

» Orange County Housing Finance Authority, Homeowner Revenue Bonds, 2006 Series A-1 (AMT) & 2006 Series A-2 (AMT)

» Orange County Housing Finance Authority, Multi-Family Housing Revenue Bonds, 2002 Series G & H (Palm Grove Gardens)

» Panhandle Regional Housing Finance Corp. TX Multi-Family Housing Revenue Bonds (GNMA Collateralized - Blue Water Gardens Apartments) 2004A & B

» Panhandle Regional Housing Finance Corp. TX Multi-Family Housing Revenue Bonds (GNMA Collateralized - Renaissance of Amarillo Apts) 2001A & B

» Penfield-Crown Oak Housing Development Corp, Multi-Family Housing Revenue Bonds (Crown Oak Apartments Project) 2006A

» Peregrine's Landing, LLC Facility Revenue Bonds (GNMA Security)Series 2002A & Taxable Series 2002B

» Permian Basin Regional Housing. Fin. Corp., TX, Multi-Family Mortgage Revenue Bonds 2006 A-1, A-2 & A-3

» Phoenix Industrial Development Authority, AZ, Multi-Family Housing Revenue Bonds (GNMA Collateralized - Escala Central City Apartments Project) 2005A

» Pima Co. & Maricopa Co. Ind. Devel. Auth. Multi-family Housing. Revenue ser. '93A (RTC Bulk Sale Program.) (FNMA coll.)

» Pinellas County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds 2004A

» Pinellas County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds 2005A

» Pinellas County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds 2006B-1 & B-2

» Pinellas County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds 2007 A1 & A2

» Pinellas County Housing Finance Authority, FL Multi-Family Mortgage Revenue Bonds2003B

» Pinellas County Housing Finance Authority, FL Series 2010A-2 Single Family Housing Revenue Bonds

» Pinellas County Housing Finance Authority, FL, Multi-Family Mortgage Revenue Bonds 2006 A-1 & A-2

» Pinellas County Housing Finance Authority, FL, Multi-Family Mortgage Revenue Bonds, 2005B

» Pinellas County Housing Finance Authority, FL, Single Family Housing Revenue Bonds (Multi-County Program) 2003 Series A

» Pittsburgh Urban Redevelopment Authority, PA, Multi-Family Housing Revenue Bonds (Eva P. Mitchell Residences Project), Series 2009, $4.400MM

» Pittsburgh Urban Redevelopment Authority, PA, Multi-Family Housing Revenue Bonds (GNMA Collateralized - West Park Court Project) 2006

» Port Arthur Housing Finance Corporation Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Heatherbrook Apartments) Series 2004

» Prince George's County Housing Authority, MD Multi-Family Housing Revenue Refunding Bond (Emerson House Project) 2005

» Providence City Housing Authority, RI, Multi-family Housing Revenue Bonds (Lockwood Plaza Project) 2002

» Providence Housing Authority, RI, Collateralized Mortgage Revenue Bonds (New Canonchet Cliffs Apartments Project) 2007A

» Rapides Finance Authority, Multi-Family Mortgage Revenue Bonds (GNMA and Fannie Mae Mortgage-Backed Securities Program), Series 1998A (AMT and Series 1998B (Non-AMT)

» Rapides Finance Authority, Multi-Family Mortgage Revenue Bonds, Series 2005A

U.S. PUBLIC FINANCE

21 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Reading Housing Authority, PA, Multi-Family Housing Mortgage Revenue Bonds (Goggle Works Apartment) Series 2010

» Region III Housing Auth. New Mexico, Inc. Multi-Family Housing Revenue Bonds (GNMA Collateralized - Vista Grande Apartments Project) Series 2003A

» Region III Housing Authority, New Mexico, Inc. Multi-Family Housing Refunding and Improvement Revenue Bonds (La Resolana Apts. Project) Ser.2005A

» Rochester Housing Authority, NY, Multi-Family Housing Revenue Bonds (GNMA Collateralized - Andrews Terrace Apartments Project) Series 2006

» Saint Paul Housing & Redevelopment Auth. MN Multi-Family Housing Revenue Bonds (GNMA Collateralized - Selby-Grotto Limited Partnership) 2003

» Saint Paul Housing & Redevelopment Auth. MN Multi-Family Housing Revenue Bonds (GNMA Collateralized - Strauss Apartments) 2002

» San Antonio Housing Fin Corp, TX Multi-Family Housing Revenue Bonds (GNMA Collateralized - Eagle Ridge Apartments Project) 2002

» San Antonio Housing Fin Corp, TX Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Southside Villas Apartments Project) 2003

» San Bernardino Co Single Family Home Mortgage Rev Ser '99A-1, '99A-2, & '99B-1

» San Bernardino County Housing Authority, CA Multi-Family Mortgage Revenue Bonds (GNMA Collateralized - Glen Aire Estate Mobilhome Park) 2001A

» San Bernardino County Housing Authority, CA Multi-Family Mortgage Revenue Bonds (GNMA Collateralized - Santiago Hillside Estate Mobilhome Park) 2003A

» San Bernardino County Housing Authority, CA Multi-Family Mortgage Revenue Bonds (GNMA Collateralized - Santiago Orangewood Estate Mobilhome Park) 2003A

» San Diego City Housing Authority, CA, Tax-Exempt Multi-Family Housing Revenue Refunding Bonds (Island Village Apartments) Series 2001B

» San Diego Housing Auth Multi-Family Housing Rev Bonds (GNMA Collateralized Pres John Adams Manor Apts) 1998 Issue B

» Santa Clara Co Housing Auth Multi-family Housing Rev Ser '99A & A-T (GNMA Collateralized-Don de Dios Apts)

» Santa Clara Co Housing Auth Multi-family Housing Rev Ser '99B & B-T (GNMA Collateralized-Village Avante Apts)

» Seattle Housing Authority, WA Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Wisteria Court Project) 2003

» Sedgwick & Shawnee (Counties of), KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2007 A-5

» Sedgwick & Shawnee (Counties of), KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2007 A-6

» Sedgwick & Shawnee (Counties of), KS Residual Revenue Bonds Series 2010 BONDS

» Sedgwick & Shawnee (Counties of), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2005 A-5

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 A-1

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 A-2

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 A-3

U.S. PUBLIC FINANCE

22 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 A-4

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 A-5

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 A-6

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 B-1

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 B-2

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2006 B-4

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2007 A-1

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2007 A-2

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2007 A-3

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program), 2006 B-3

» Sedgwick & Shawnee (Counties of ), KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program), 2007 A-4

» Sedgwick & Shawnee Cos. Collateralized single family mtge. Revenue Refunding ser. '94A-I (AMT), B-I & C-I (GNMA)

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002 B-2

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002 B-3

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002 B-4

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002 B-5

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002A-1

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002A-2

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002A-3

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002A-4

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002A-5

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2002B-1

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2003 A-1

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2003 A-2

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2003 A-3

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2003 A-4

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2003 A-5

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2004A-1

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2004A-2

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2004A-3

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2004A-4

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2004A-5

U.S. PUBLIC FINANCE

23 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2004A-6

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2005A-1

» Sedgwick & Shawnee Counties, KS Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) 2005A-2

» Sedgwick & Shawnee Counties, KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program), 2005 A-3

» Sedgwick & Shawnee Counties, KS, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program), 2005 A-4

» Sedgwick County Kansas, Shawnee County Kansas, and Reno County Kansas, GNMA Collateralized Multi-Family Mortgage Revenue Bonds, Series 1995A

» Sedgwick County, Kansas and Shawnee County, Kansas, Multi-Family Mortgage Revenue Bonds (Mortgage-Backed Securities Program) Series 2006 B-5

» Sedgwick County, Kansas and Shawnee County, Kansas, Multi-Family Mortgage Revenue Bonds 1997 Series A-1, A-2 & A-3

» Shoreview (City of) MN Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Lexington Shores Project) 2001A & B

» South Carolina State Housing Finance & Development Authority Multi-Family Housing Revenue Bonds (Greenville Apts.)

» South Carolina State Housing Finance & Development Authority Multi-Family Housing Revenue Bonds (Hillendale Apts.)

» South Carolina State Housing Finance & Development Authority Multi-Family Housing Revenue Bonds (Beverly Apts.)

» South Plains Housing Finance Corporation, TX, Multi-Family Mortgage Revenue Bonds (Guaranteed Mortgage-Backed Securities , 2007-A

» Southeast Texas Housing Finance Corporation, Single Family Mortgage Revenue and Refunding Bonds (Guaranteed Mortgage-Backed Securities Program) Series 2006A-1, Series A-3

» Special Limited Obligation Multi-Family Housing Development Bonds (Mantua - Phase II) Series 2010Q

» Special Limited Obligation Multi-Family Housing Development Notes (Paschall – Phase II)

» Spokane (WA) Housing Authority Nonprofit Elderly Revenue Bonds (GNMA Collateralized - Cheney Care Center Project), Ser 1998A

» Springfield (Township of) OH Mortgage Revenue Bonds (GNMA Collateralized - Burney View Apartments Project) Series 2003A and B

» St. Paul Housing & Redevelopment Auth., MN Multi-Family (GNMA Collateralized - Franciscan Health & Housing Services) 2002

» State of Oregon Housing Community Services Department Housing Development Revenue Bonds, 2003 Series A (The Tower at Station Place Project)

» Sullivan (County of) TN, Health Ed & Housing Facility Bonds Multi-Family Housing Revenue Refunding Bonds (Maple Oak Apartments) 2003

» Summit County Port Auth Multi-Family Housing Revenue Bonds (GNMA Collateralized - Eastland Woods Project) 2004A & B

» Summit County Port Authority, OH Multi-Family Revenue Bonds (GNMA Collateralized - Callis Tower Project) 2007A

» Summit County Port Authority, OH, Multi-Family Housing Revenue Bonds (GNMA Collateralized - Collinson Apartments Project) 2006A

U.S. PUBLIC FINANCE

24 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» Tarrant (County of), TX Health Facility Development Corp Mort Rev Bonds (GNMA Collateralized - Multiple Projects - Mission Oak, et al)

» Tarrant County Cultural Education Facilities Finance Corp. Retirement Facility Revenue Bonds (GNMA Mortgage Loan WGH Heritage, Inc Project) Series 2008A-1 and Taxable Series 2008A-2

» Tarrant County Housing Finance Corporation, Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Amelia Parc Senior Apartments) Series 2007

» Tarrant County Housing. Fin. Corp., TX Multi-Family (GNMA Collateralized - Arlington Seniors Apts) 2002

» Texas Dept. of Housing & Community Affairs, Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Prairie Ranch Apartments) 2005

» Texas Dept. of Housing & Community Affairs, Multi-Family Housing Revenue Bonds (GNMA Collateralized Mortgage Loan - Villas at Mesquite Creek Project), 2007 A&B

» Texas State Affordable Housing Corporation Multi-Family Mortgage Revenue Bonds (Professional Educators Home Loan Program) 2005A

» Texas State Affordable Housing Corporation Multi-Family Mortgage Revenue Bonds (Professional Educators Home Loan Program) 2005B

» Texas State Affordable Housing Corporation Multi-Family Mortgage Revenue Bonds 2009A, 2009B, 2010A, 2011B

» The City of Palm Springs, Multi-Family Mortgage Revenue Bonds (GNMA Collateralized - Sunrise Village Mobile home Park Project) Series 2004A and Taxable Series 2004B

» The Community Redevelopment Agency of the City of Los Angeles, California, Multi-Family Housing Revenue Bonds (GNMA Mortgage-Backed Securities Program—Pico Union Scattered-Site Preservation Apartments) Series 2002 & 2002-T

» The Housing Authority of the City of Jackson, Mississippi, Multi-Family Housing Mortgage Revenue Bonds, Series 2002 (GNMA Collateralized – Forest Park Apartments)

» The Industrial Development Authority of the City of Tolleson, Arizona Multi-Family Housing Revenue Bonds (GNMA Collateralized-Copper Cove Apartments Project) Series 2001A

» The Unified Government of Wyandotte County/Kansas City, Kansas Multi-Family Housing Refunding Revenue Bonds, Series 2004 (Brookstone Apartments Project)

» Thief River Falls, (City of), MN Multi-family Housing Rev Bonds (GNMA Collateralized - Northland Village Apts), Ser 2000

» Third Columbus Housing Development Corporation, Multi-Family Housing Refunding Revenue Bonds Series 1992A, (FHA Mortgage Loan - Renaissance Villa Section 8 Assisted Project)

» Trumbull (County of) Ohio Multi-Family Housing Revenue Bonds (Royal Mall Apartments Projects) 2007A

» Tucson & Pima County Ind. Dev. Auth., AZ, Joint Multi-Family Mortgage Revenue Bonds, 2007 B

» Tucson & Pima County Ind. Dev. Auth., AZ, Multi-Family Mortgage Revenue Bonds, 2006 A-1, A-2, & B

» Tucson & Pima County Ind. Dev. Auth., AZ, Multi-Family Mortgage Revenue Bonds, 2007 A

» Tucson & Pima County Ind. Dev. Auth., AZ, Multi-Family Mortgage Revenue Bonds, 2008 A

» Tucson (City of) AZ, Industrial Devel. Auth., Senior Living Revenue Bonds (GNMA Coll. Mortgage Loan-Casa De Encanto Apts. Project.) 2007

U.S. PUBLIC FINANCE

25 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

» UNM Sandoval Regional Medical Center, Inc., Multi-Family Bonds, Series 2010

» Utah Housing Corporation (GNMA Collateralized) Mortgage Revenue Bonds, (The Bluffs Apartments Project), Series 2002A and Taxable Series 2002A-T

» Utah Housing Corporation GNMA Collateralized Mortgage Revenue Bonds (Canyon View Apartments Project) Series 2002A and Taxable Series 2002A-T

» Utah Housing Corporation GNMA Collateralized Mortgage Revenue Bonds (Fireclay II Apartments Project) 2011 Series A and 2009 Series A

» Utah Housing Corporation GNMA Collateralized Mortgage Revenue Bonds (Foxboro Terrace Apartments Project) Series 2004A

» Utah Housing Corporation Multi-Family Housing - Coppergate Apartments Project (GNMA)

» Utah Housing Corporation Multi-Family Housing - Haven Pointe Project, Series 2005

» Utah Housing Corporation Multi-Family Housing - Park Gate Apartment Project Series 2005

» Vallejo (City of) Multi-Family Housing Rev Bond (GNMA MBS Program) Ser 1998A

» Valley Health Development Corporation Mortgage Revenue Refunding Bonds (GNMA Collateralized - Valley Health Services Project), Series 2000A & B

» Village of East Rochester Housing Authority, NY, Revenue Refunding Bonds (GNMA Security- Genesee Valley Presbyterian Nursing Center Project), Series 2001

» Village of Waynesville, Ohio, Health Care Facilities Revenue Bonds, Series 2001A (GNMA Collateralized - Quaker Heights Project)

» Washington State Housing Finance Commission (Alaska House Apartment Project), WA

» Washington State Housing Finance Commission (International House Apartment Project)

» Washington State Housing Finance Commission Multi-Family Housing Revenue Bonds (Stonebrook Apartments Project) 2003A & B

» Washington State Housing Finance Commission Multi-Family Housing Revenue Bonds (Stonebrook II Apartments Project) 2004

» Washington State Housing Finance Commission Multi-Family Mortgage Revenue Bonds (GNMA Mortgage Backed Securities Program - Parkway Apartments Project) Series 2002A & B

» Washington State Housing Finance Commission Multi-Family Mortgage Revenue Bonds (GNMA Mortgage Backed Securities Program: Tashiro-Kaplan Apartments Project) Series 2003A (AMT) and Series 2003B (Taxable)

» Waukesha City Redevelopment Authority, WI GNMA Collateralized Development Revenue Bonds (Avalon Square, Inc. Project) 2001A

» Willoughby (City of) OH Multi-Family (GNMA Collateralized - Oak Hill Apts Project) 2002

» Yonkers Industrial Development Authority, NY, GNMA Collateralized Mortgage Housing Revenue Bonds (11-23 St. Casmir Avenue) Series 2000A

U.S. PUBLIC FINANCE

26 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

Moody’s Related Research

Special Comment:

» Failure to Adhere to Legal Documents May Result in Rating Downgrades for Local Housing Transactions, October 2010 (126504)

Rating Methodologies:

» Methodology Update: Ratings that Rely on Guaranteed Investment Contracts, December 2008 (113914)

» Strength in Structure: Moody’s Approach to Rating Single-Family Housing Bonds Secured by Mortgage-Backed Securities, October 1998 (38066)

» Moody’s Analytical Approach to Rating Single Family Monthly Pass-Through Housing Bonds Secured by Mortgage-Backed Securities, September 2004 (88769)

» Moody’s Approach to Acquisition Period Extensions in Single-Family Mortgage Revenue Bond Transactions, September 1999 (49064)

» Moody’s Approach To Extensions In GNMA-Collateralized Multifamily Housing Bonds, October 2002 (76381)

» Mandatory Redemptions in GNMA Collateralized Multifamily Transactions, December 2003 (80812)

» Refinement of Moody's Approach to Rating Fixed Rate Multifamily Bonds Supported by Fannie Mae Credit Enhancement Instrument (Standby), September 2003 (79460)

» Fixed Rate Multifamily Housing Bonds Secured By Fannie Mae’s Stand-By Credit Enhancement Instrument, November 2006 (100385)

» Moody’s Currently Rates Standard FHA Multi-Family and Health Care Transactions Aa2; Risk of Non-Defined Time Period for Claims Payment Is Reflected in the Rating, December 2008 (38997)

» Payment of Fees in Housing Transactions and their Potential Impact on Ratings, December 2003 (80848)

» Bankruptcy Issues in Multifamily Housing Bonds, August 2002 (75701)

To access any of these reports, click on the entry above. Note that these references are current as of the date of publication of this report and that more recent reports may be available. All research may not be available to all clients.

U.S. PUBLIC FINANCE

27 MARCH 19, 2012

REQUEST FOR COMMENT: PROPOSED CHANGES TO METHODOLOGY FOR STAND-ALONE HOUSING TRANSACTIONS WITH MORTGAGE ENHANCEMENTS

Report Number: 139421

Author Gregory W. Lipitz

Production Associate David Dombrovskis

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