Ginnie Mae VA RFI Final

Transcript

1 Request for Input Pooling Eligibility Changes

2 TABLE OF CONTENTS Overview 3 ... ... 3 Background ... 6 Issue to Address For Consideration Input Sought ... 7 Topic 1 ... 7 ... 7 Topic 2 Topic 3 ... 7 Topic 4 ... 7 Instruction for Submitting Input ... 8 Important Notes 8 ... Appendices ... 9 Appendix I ... 9 Appendix II ... 10 ... 11 Appendix IV Appendix V ... 12 Appendix VI ... 13 Appendix VII 14 ... | 2 Request for Input: Pooling Eligibility Changes Ginnie Mae |

3 Overview Ginnie Mae is considering making changes to the parameters governing loan eligibility for pool types and is soliciting input from stakeholders about the impacts of potential changes. Background of Veterans Affairs (VA) loans could be rapidly prepaid by a The Ginnie Mae II Multi-Issuer Program (GII MIP) today 2 represents nearly one-third of agency mortgage-backed and the counterparty risk streamlined refinance process, that arose when Issuers specialized in such products and security (MBS) issuance and is a vehicle for the funding constructed overly-concentrated servicing portfolios. More of origination under the federal government’s single- recently, Ginnie has expanded its focus, and is considering family loan insurance/guaranty programs. One of the key additional policy actions as described below. features distinguishing the GII MIP is the fact that it is an aggregation of production from a wide variety of lender/ The actual and projected extent of loan prepayment servicer Issuers and is comprised of a broad base of loan is a primary concern of MBS investors and analysts, characteristics. Purchasers of GII MIP securities have 1 particularly when an above-par price has been paid for the invested in a pro-rata share of large mortgage pools security in which the prepayment occurs. Prepayment risk that are representative of current production within the government-insured or guaranteed lending sector. Strong is a well-understood feature of the MBS asset class and is market acceptance of the GII MIP has been critical in the subject of extensive loan-level analysis that supports enabling Ginnie Mae to fulfill its mission of facilitating low- the liquidity of the securities. However, for security investors, concerns arise when investment losses are cost financing for American homeowners and the federal housing finance programs it’s intended to serve. borne as the result of refinance activity that appears not to correlate with economic fundamentals. Ginnie Mae is vigilant about any trend that impairs investor confidence in the GII MIP. Ginnie Mae monitors Recently, Ginnie Mae has focused on certain adverse activity centered on refinance loans within the underlying trends in how some GII MIP securities were trading 3 It’s relative to the securities issued by Fannie Mae. federal loan or guarantee programs. Originally, this effort concerned the ease with which newly-created Department clear from published analysis and investor commentary 1 Please see Appendix I showing Issuance Volumes Issuance of Ginnie Mae securities backed by Single-Family loans for January, February, and March 2019. , which restricted streamline refinances of loans on which fewer than six consecutive monthly 2 In 2016, Ginnie Mae published APM 16-05: Pooling Eligibility for Streamlined Refinance Loans payments had been made from accessing the GII MIP. 3 Please see Appendix II below. | 3 Request for Input: Pooling Eligibility Changes Ginnie Mae |

4 that GII MIP securities were believed to be susceptible to refinance activity out of proportion to what should be expected from prevailing economic conditions. Non-correlated VA refinance Ginnie Mae’s concern, then and now, is that investor activity continues to be evident, trepidation about this activity will negatively impact investor confidence in the performance of the securities and the extent to which it is a and the relative price that they receive in the market. focus of analysts and investors Deterioration in market pricing translates directly is unhealthy for Ginnie Mae’s into a higher cost of homeownership for the homeowners the Ginnie Mae MBS program is ability to fulfill its mission. intended to serve. The consumer protection aspects of the situation have been the recipient of attention from policymakers, and to date the following actions have been taken by Congress, In 2018, in addition to these program eligibility changes, Ginnie Mae and the VA to curb the behavior of rapid Ginnie Mae identified security performance as being refinancing in the VA program subject to standards of acceptable risk and began reviewing security performance at the Issuer level and restricting Issuers whose performance deviated Ginnie Mae All Participants Memoranda substantially from cohort performance. implemented a (APM) 16-05 (October 2016) six-month seasoning requirement for streamline refinance loans to be eligible for pooling in the GII Ginnie Mae believes that taken together these policy MIP. APM 17-06 (December 2017) modified the actions have probably had moderate success in definition of the seasoning period and extended lessening uncorrelated refinance spikes, but that there is the requirement to cash-out refinance loans and 4 securities. Ginnie Mae I not yet reasonable assurance that the safeguards now in place are sufficient. Non-correlated VA refinance activity Public Law 115-174 (May 2018) imposed new continues to be evident, and the extent to which it is a requirements on loans to veterans, and codified in law the seasoning requirement earlier focus of analysts and investors is unhealthy for Ginnie 5 imposed by Ginnie Mae. Mae’s ability to fulfill its mission. VA Interim Final Rule RIN 2900 AQ42 (December 2018) imposed new requirements Ginnie Mae is undertaking a comprehensive review of loan on cash-out refinances, which had not been data seeking a better understanding of the ways in which addressed in PL 115-174. loan type categories performed differently from one another. 4 The Ginnie Mae I MBS Program is a mortgage-backed securities program comprised of single-Issuer securities, in which the timely payment of principal and interest on the securities is guaranteed by Ginnie Mae to occur on the 15th day of each month (or, in the case of payment by electronic funds transfer, if the 15th is not a business day, the next business day). In contrast, the Ginnie Mae II MBS Program allows loan packages from multiple Issuers to serve as collateral for a single security. 5 Though on slightly different terms than the original Ginnie Mae language. Ginnie Mae issued APMs 18-04 and 19-02 to reflect and clarify program terms affected by PL 115-174 | 4 Request for Input: Pooling Eligibility Changes Ginnie Mae |

5 This review is based on pooling and monthly reporting data programs. Program differences among the agency from January 2017 through March 2019. The initial results program sponsors are not inherently problematic, are summarized in greater detail in Appendices III through and melding different loan types within the GII MIP VI and indicate the following: is, as noted, one of the purposes of the MIP program. However, it has come to Ginnie Mae’s attention that despite the differences in program requirements for Refinance loans liquidate with greater refinances, there are additional dynamics at play, 6 frequency than purchase loans. particularly as it relates to prepayment speeds and VA refinance liquidations on average, occur performance of the GII security. earlier than do Federal Housing Authority 7 (FHA) refinance liquidations. Given the impact we believe this continues to have Liquidations of VA cash-out refinance loans, on the GII MIP, Ginnie Mae is therefore exploring the with higher loan-to-value ratios (LTV) generally possibility of further actions, and this Request for Input liquidate with greater frequency and have a greater impact on prepayments than FHA cash- (RFI) is to give program stakeholders and observers 8 outs at the same loan to value ranges. an opportunity to provide analysis and insight to inform Ginnie Mae’s consideration of the issues involved. The loans analyzed in the review and detailed in the Appendices were originated at differing times relative to the prior policy actions noted above, and in particular One of the primary the VA rule is so recent that it is too soon to determine observations of the review the impact it would have on this particular analysis. is that there are substantial One of the primary observations of the review is that there are substantial differences between how the differences between how the Federal Housing Administration and VA loans perform FHA and VA loans perform when securitized, some of which may be attributable to the parameter differences between the two refinance when securitized. See Appendix III 6 See Appendix IV 7 8 See Appendix V Request for Input: Pooling Eligibility Changes Ginnie Mae | | 5

6 ISSUE TO ADDRESS FOR CONSIDERATION Ginnie Mae is confronting a situation in which the GII The initial review summarized in the Appendices indicates MIP, because of the combination of greater volume of VA that VA cash-out refinance loans have a particularly high 10 loans and present-day borrowing/lending practices, is propensity to prepay rapidly in large part because the LTV being utilized to support short-term consumer financing requirements for cash-out refinances in the VA program for veterans to a greater degree than has previously been are different from those of the FHA program and the the case. As noted earlier, this situation may be having government-sponsored enterprises (GSEs). an adverse impact on the prices paid for these securities, and thereby resulting in cross-subsidization of high-LTV Two areas for consideration arise from this analysis. cash-out refinancing by the residual FHA, VA and United One concerns the need to ensure that loans made serve States Department of Agriculture (USDA) borrowers the interests of the veteran homeowners – this concern whose loans are commingled in the GII MIP. was the basis for both Public Law 115-174 and VA’s recent interim final rule, the effectiveness of which will Ginnie Mae is therefore evaluating the possibility of continue to be evaluated by market participants. excluding from (or restricting within) the GII MIP loan type categories that can be expected to prepay at The second issue concerns the extent to which the significantly higher rates from the loan types whose more lenient VA requirements are fostering short-term performance is better correlated with market trends borrowing patterns that are at odds with the purpose of and the intended purpose of the GII MIP securities. the GII MIP program. Ginnie Mae’s view of the GII MIP products is that they are intended for loans in which the average lifespan can be expected to align with ownership For consideration is the potential for VA of a property, adjusted for the periodic opportunity to cash-out refinances in excess of 90% improve loan terms when interest rate cycles permit. loan-to-value to be excluded, or restricted, from the multi-Issuer pools , given their Cash-out refinances serve a role for borrowers, but performance history in the securities and the traditionally only on a smaller scale, as the FHA and program requirement differences relative to the GSEs require more stringent loan-to-value ratios for FHA and the GSEs. 9 cash-out refis relative to the VA program. For a fixed rate fully-amortizing cash-out loan on a principal residence, Fannie Mae and Freddie Mac impose an 80% L 9 TV maximum. Please see Fannie Mae’s Eligibility Matrix, accessible at https://www.fanniemae.com/content/eligibility_information/eligibility-matrix.pdf , and Freddie Mac’s Maximum LTV/TLTV/HTLTV Ratio Requirements for Conforming and Super Conforming . http://www.freddiemac.com/singlefamily/factsheets/sell/ltv_tltv.htm Mortgages accessible at VA loans constitute a substantial subsegment of Ginnie Mae’s monthly issuance. For the months of January, February and March 2019, VA loans accounted for 38.6%, 38.79% and 41% of 10 Ginnie Mae’s issuance volume, respectively. | 6 Request for Input: Pooling Eligibility Changes Ginnie Mae |

7 The logical possibilities for an alternative path are: Ginnie Mae reserves the right to overlay its own requirements about acceptable loan characteristics on those of the insuring/guaranteeing agencies when Single-Issuer custom securities. it deems the performance of the Ginnie Mae MBS standard de minimis Imposition of a securities is being negatively impacted. restricting inclusion in the MIP. specifically for shorter Creation of a new MIP An additional topic for consideration is the securitization duration loan type categories. path for excluded (or restricted) loan type categories. In accordance with its mission, Ginnie Mae would seek to provide an alternative securitization path that provided This evaluation involves complex cause-and-effect for liquidity to the maximum extent possible, while also issues, and projections about market-driven impacts, providing full market transparency. about which Ginnie Mae is soliciting input from stakeholders relating to the questions identified in the following section. INPUT SOUGHT than 90% is an appropriate threshold for identifying Responders may provide input on any of the following the loan type category that would be subject to an topics and expand on the topics as seems appropriate alternative securitization path. to address related questions or implication that are not directly articulated below. Topic 3 Analysis is sought on the impact of an increased Topic 1 propensity of high-LTV VA cash-out refinances to prepay Input is sought on the extent to which varying on the pricing of the GII MIP, and on the residual GII prepayment performance by different loan type categories within the GII MIP should be considered MIP production. This might include analysis of the acceptable. Commentary may be provided on projected pricing of the GII MIP if high-LTV VA cash-outs attendant issues of homogeneity and subsidization. were excluded or restricted. Topic 2 Topic 4 Input is sought on the alternative path possibilities Additional analysis is welcomed on the propensity of high-LTV VA cash-out refinances to prepay, in for the subject loan type category, including as to comparison with those of other loan type categories. the marketability, pricing, liquidity and TBA market Commentary may be provided on whether LTV greater implications of each. Ginnie Mae | | 7 Request for Input: Pooling Eligibility Changes

8 Instruction For Submitting Input with the law and apply any FOIA exemptions that may transmit Ginnie Mae asks that each respondent responses via email no later than 3:00 p.m. Eastern apply. If you wish HUD and Ginnie Mae to consider Time on May 22, 2019 to [email protected] any portion of your response exempt from disclosure under the FOIA, you should clearly mark that portion as gov . Ginnie Mae acknowledges that any responses are “confidential commercial information.” provided completely on a voluntary basis and responses are not required for participation in any federal program. Please include the following in your response the Please clearly mark all responses with “Voluntary following information: response provided to HUD in response to an RFI. This is not a required submission for participation in a federal program.” Any responses provided to Ginnie Mae Name(s) or organization(s) and addresses. may be subject to release subject to the Freedom of Contact information. Information Act (FOIA). Should responses be responsive to a FOIA request, HUD will process in accordance Important Notes (Disclaimer) provided. This RFI should not be construed as a This RFI is not a request for proposal, request for commitment by Ginnie Mae. All information contained quotation, offer or an invitation for bid, nor does its in the RFI is preliminary and is subject to modification issuance restrict the Government on its eventual activities. This is an RFI only, and all information and is in no way binding on the Government. The Government will not pay for information received received will be used for planning and market research purposes only. Information received will in response to this RFI. Responders to this RFI are solely responsible for all expenses associated with not be published. Respondents will not be notified of responding to this RFI. any results derived from a review of the information Request for Input: Pooling Eligibility Changes | 8 Ginnie Mae |

9 Appendix I CY 2019 Single-Family Issuance Volumes by Loan Purpose $30,000 $25,000 $20,000 $15,000 $10,000 $5,000 $0 March February January Refinance HAMP Mod Purchase Non-HAMP Mod Loan Purpose March February January (Insurance Amount(s) in millions) $16,943 $15,844 Purchase $20,858 Refinance $6,319 $5,887 $7,738 $663 Non-HAMP Mod $581 $724 HAMP Mod $491 $585 $496 Form HUD 11706 issuance data Jan 2019 through March 2019. Data source: | 9 Request for Input: Pooling Eligibility Changes Ginnie Mae |

10 Appendix II G2 vs FN Swaps October 2018 Through April 2019 1.50 1.25 1.00 0.75 0.50 0.25 0.00 (0.25) (0.50) (0.75) (1.00) (1.25) (1.50) (1.75) (2.00) Oct-18 Apr-19 Apr-19 Apr-19 Apr-19 Jan-19 Jan-19 Jan-19 Jan-19 Jan-19 Mar-19 Mar-19 Mar-19 Mar-19 Feb-19 Feb-19 Feb-19 Feb-19 Nov-18 Dec-18 Dec-18 Dec-18 Dec-18 Nov-18 Nov-18 Nov-18 5.0 4.0 3.0 3.5 4.5 5.5 Bloomberg. Data source: | 10 Request for Input: Pooling Eligibility Changes Ginnie Mae |

11 Appendix III % of Liquidated Principal of Total OPB at Issuance by Loan Purpose for Single- Family Fixed Rate Loans in Pools Issued from January 2017 through December 2018 3.5 Coupon 4.0 Coupon 20% 20% 15% 15% 10% 10% 5% 5% 0% 0% Cash-Out Non-Streamline Purchase Cash-Out Non-Streamline Streamline Purchase Streamline 5.0 Coupon 4.5 Coupon 20% 30% 25% 15% 20% 10% 15% 10% 5% 5% 0% 0% Purchase Streamline Non-Streamline Cash-Out Purchase Streamline Non-Streamline Cash-Out Data source: Form HUD 11706 issuance data Jan 2017 - Dec 2018 and liquidations data reported in Ginnie Mae’s Reporting and Feedback System (RFS) through Mar 2019. Ginnie Mae | Request for Input: Pooling Eligibility Changes | 11

12 Appendix IV Comparison of Average Loan Age at Liquidation for All FHA Refinance Loans and All VA Refinance Loans for Single-Family Fixed Rate Loans in Pools Issued from January 2017 through December 2018 VA Avg. Loan Age Coupon Refinance FHA Avg. Loan Age Rate (Months) Purpose Code (Months) Non-Streamline 3.5% 12.95 11.23 10.15 14.96 4.0% 35.81 4.5% 23.99 5.0% 72.64 26.71 Cash-Out 3.5% 10.98 10.01 4.0% 8.04 10.25 4.5% 11.24 7.45 5.0% 16.24 7.99 11.30 3.5% 13.88 Streamline 15.72 15.71 4.0% 4.5% 38.86 36.09 52.81 101.29 5.0% Form HUD 11706 issuance data Jan 2017 - Dec 2018 and liquidations data reported in Ginnie Mae’s Reporting and Feedback System (RFS) through Mar 2019. All Refinance codes Data source: . (Streamlined, Cash-out, Non-Streamlined) are included for each agency | 12 Request for Input: Pooling Eligibility Changes Ginnie Mae |

13 Appendix V Comparison of FHA Cash-Out and VA Cash-Out Liquidation Rates for Various LTV Ranges for Single-Family Fixed Rate Loans in Pools Issued from January 2017 through December 2018 LTV Avg. FHA Coupon VA FHA VA Avg. Cash-Out Cash-Out Cash-Out Loan Age Rate Loan Age Cash-Out Bracket Liquidation Liquidated Liquidated Liquidation Loan Count Loan Count Rate Rate 100.01+ 3.5 0.1% 5.67 1,139 1.0% 9.99 3 34 0.0% 18.15 4,848 2.4% 9.70 95.01 - 100 90.01 - 95 24 0.0% 9.08 1,911 5.0% 10.12 85.01 - 90 7,733 11.24 3,256 7.9% 10.37 8.8% 3,623 1,650 11.01 80.01 - 85 7.5% 10.19 8.5% 00.00 - 80 7.7% 10.64 4,034 6.8% 9.98 7,053 N/A - 0.0% 0.00 - 0.0% 0.00 Category 2.4% 10.98 16,838 3.5% 10.01 18,470 7.80 100.01+ 3 0.0% 12.67 1,256 1.4% 4 95.01 - 100 7.55 32 0.0% 32.31 4,105 2.7% 90.01 - 95 33 1,258 6.1% 8.28 0.1% 29.30 9.1% 8.3% 1,593 6,673 8.55 85.01 - 90 10.61 3,080 9.97 735 7.1% 8.45 80.01 - 85 8.9% 5,670 7.5% 9.75 1,698 6.5% 8.56 00.00 - 80 - 0.00 - 0.0% 0.00 0.0% N/A 15,491 2.0% 10.25 10,645 3.3% 8.04 Category 4.5 100.01+ - 0.0% 0.00 785 1.8% 7.56 95.01 - 100 58 80.83 4,471 5.8% 7.23 0.0% 90.01 - 95 0.2% 75.94 831 10.8% 7.97 31 85.01 - 90 2,566 7.1% 11.00 718 10.4% 7.65 80.01 - 85 6.9% 10.43 411 10.8% 7.54 1,119 7.73 2,717 7.8% 9.58 905 9.8% 00.00 - 80 0.00 N/A - 0.0% 0.00 - 0.0% 11.24 1.5% 6,491 Category 5.5% 8,121 7.45 HUD 11706 pooling data from January 1, 2017 through December 1, 2018 and reporting data from January 1, 2017 through March 1, 2019. Calculation reflects total Data source: liquidations of FHA purchase loans originated during that two year window (in that coupon rate and LTV Bucket) divided by total originations of FHA purchase loans during that two year window (in that coupon rate and LTV bucket). | 13 Request for Input: Pooling Eligibility Changes Ginnie Mae |

14 Appendix VI Comparison of FHA Cash-Out and VA Cash-Out Underwriting Requirements VA Cash-Out FHA Cash-Out 11 Max LTV 96.75-100% 85% Six Payments and 210 Seasoning/Ownership 12 months Ownership/ 12 Days Occupancy Requirements Appraisal Needed Ye s Ye s One of 8 NTB Needed to Net Tangible None 13 Pass Test Benefit Test Data source: HUD Handbook 4155.1, Chapter 3, Section B. et seq. accessible at https://www.hud.gov/sites/documents/4155-1_3_SECB.PDF ; VA Circular 26-18-30 (Dec. 19, 2018), accessible at https://www.benefits.va.gov/homeloans/documents/circulars/26_18_30.pdf 11 LTV maximum is 100% including the funding fee. Hence, the maximum LTV will depend on applicable VA funding fee. Disabled veterans have no funding fee, other veterans have a funding fee that ranges from 2.15% for first use to 3.3% for subsequent use. 12 Additional restrictions apply for borrowers who have owned the property for less than 12 months For a loan to pass the NTB test, it would have to satisfy one of the following: eliminates monthly mortgage insurance, refinances an interim construction loan, decreases the loan term, reduces the 13 interest rate, decreases the monthly payment, increases monthly residual income, loan-to-Value (LTV) is equal to or less than 90 percent, or refinances from an adjustable rate (ARM) to fixed rate. Request for Input: Pooling Eligibility Changes Ginnie Mae | | 14

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