SCHUMER conmrees
JOINT ECONOMIC
Wnited States Senate weeny
June 26, 2008
Ronald Rosenfeld Dean Schultz
Chairman President and Chief Executive Officer
Federal Housing Finance Board, Federal Home Loan Bank of San Francisco
1625 Eye Street NW 600 California St, #2
Washington, DC 20006 San Francisco, CA 94108
Dear Chairman Rosenfeld and President Schultz,
Iam writing to you out of concem for the safety and soundness risks posed by
IndyMac Bancorp, Inc., one of the largest independent mortgage lenders in the United
States. I am concemed that IndyMae’s financial deterioration poses significant risks to
both taxpayers and borrowers, and that the regulatory community may not be prepared to
take measures that would help prevent the collapse of IndyMac or minimize the damage
should such a failure occur.
‘There are clear indications that IndyMac may have serious problems with its
current loan holdings, and could face a failure if prescriptive measures are not taken
quickly. IndyMac’s stock price has dropped almost 95 percent in the past year and its
new loan production has fallen by almost two-thirds in the past year. As you know,
Moody’s Investors Service recently downgraded its servicer quality rating because of
concerns about inadequate capital and wamed of further downgrades.
You may recall that late last year I wrote to Chairman Rosenfeld expressing my
concem about the quality of Countrywide’s pledged collateral, and given the rapid
deterioration of Countrywide’s loans I was glad to see that measures were taken to cur
advances to Countrywide. I fear that IndyMac’s financial situation is even worse than
Countrywide’s was at the time of my writing. As of March 31, 2008, IndyMac’s portfolio
had an 11 percent delinquency rate, twice that of the beleaguered Countrywide, due
largely to irresponsible lending practices. Because IndyMac holds over $10 billion dollars
in advances from the Federal Home Loan Bank, I ask that you conduct a careful review
of loans that are being held as collateral for FHLB advances.
Specifically, I would like to know what steps FHLB San Francisco and the
Federal Housing Finance Board are taking in response to IndyMae’s financial trouble.
First, have you verified that IndyMac’s deposits are not supporting loans that do not meet
the Joint Banking Guidelines on ability to repay and documentation? Second, has the
Bank taken steps to determine that the credit and collateral terms for the advances made
to IndyMac accurately reflect the associated risks? Have there been, for example, recent
field reviews of pledged collateral or management controls, or changes in financingavailability or margins? Third, does the bank plan future actions to mitigate the risks of
its exposure to IndyMac?
‘Thank you for your consideration of this matter, and I look forward to your
prompt response to the concems that I have raised, Please don’t hesitate to contact
myself, or David Stoopler of my staff with any information or questions at 202-224-6542.
Sincerely,
Charles Schumer dene
United States Senator