The GSEs’ credit-risk sharing program has expanded over the years but not everyone has been fond of the transactions designed to transfer risk away from Fannie Mae and Freddie Mac Tim Howard, a former Fannie CFO, has become one of the program’s biggest critics. He said today’s credit-risk transfer program, mandated by the Federal Housing Finance Agency, removes the “normal economic discipline” of a company making its own decisions about which risks to keep and which ones to share, and on what terms. He said that the CRT transactions being done today are nothing like those done during his time at Fannie, before the start of the conservatorship.