Situation Audit

The Federal National Mortgage Association, also known as Fannie Mae or FNMA, was founded by Congress to provide a reliable and consistent source of lending for home purchases.  Although it started out as a government agency, in the 1960’s it became an independent organization.  With the collapse of the housing market, FNMA was taken into conservatorship where it has remained until today.  The vision of FNMA is to be “America’s most valued housing partner” (Fannie Mae, 2019a).  This concurs with the organizational mission to provide affordability, liquidity, and stability to the U.S. housing market (FNMA, 2011).  After being taken into conservatorship by the Federal Housing Finance Agency (FHFA; 2019), FNMA has followed a balanced scorecard which contains goals to continue to improve liquidity, reduce risk, provide home loans for those with low incomes, and to fortify the systems that the organizations use to service their customers.  FNMA grew their staff to meet the increased need for services in resolving foreclosures but has since been drawing down the size of the organization (FNMA, 2018b).  The major strength of FNMA is their connection to the federal government and virtually limited financial resources.  However, the position of being in conservatorship has placed serious limitations on the organization to attract new talent, due to limitations in the ability to provide attractive compensation packages.  Senior management has done well in improving customer relationship through the Way of Working management program, which has improved customers’ likelihood to recommend the organization.  This also demonstrates the organization's ability to learn and adapt.  The limitations compensation flexibility, both at the senior management and employee levels indicates that FNMA needs to find creative new approaches to improve employee satisfaction to keep key employees.  All indications suggest that FNMA will continue to succeed if they follow their current trajectory.

Situation Audit

A situation analysis is a formal process which assesses an organization’s recent history and current situation.  As Ramanujam, Venkatraman, and Camillus (1986) explain, a situation analysis, which can also be referred to as an appraisal, is a close examination of an organization’s internal capabilities in an effort to determine the strengths and weaknesses inherent therein.  Such an analysis is required because business planning can fail if the internal aspects of the organization have not been adequately or correctly assessed.  Failure to identify key business weaknesses could lead to overlooking them, which jeopardizes any plans that do not take those limitations into consideration.  The business plans that will emerge from this situation audit will be designed to help the organization to adapt to the environmental demands and pressures that it is experiencing. 

This situational analysis is of the Federal National Mortgage Association, commonly referred to as Fannie Mae or FNMA.  The analysis will start with a factual overview, which will outline the history and purpose of the organization.  This will be followed by a consideration of FNMA’s mission, vision, values, and goals.  These will be critical because the rest of the situational analysis will be conducted to determine how well FNMA is designed to achieve these stated mission, vision, values, and goals.  This will be followed by an analysis of the strategy and objectives, and how well these strategies contribute to a strategic advantage for the organization.  The critical resources will be identified, along with any impediments in achieving the stated goals and objectives.  This will be followed by a consideration of the organizational size, structure, and critical resources needed to achieve the goals and objectives.  The leadership, governance, and management will be analyzed to determine any deficits.  This will be followed by an analysis of strengths and weaknesses, along with the organization’s demonstrated ability to learn and change.  The findings of this study will inform the recommendations and conclusions provided at the end of this report.

Fact Sheet

Fannie Mae (FNMA) was formed during the Great Depression in order to provide a source for consistent, dependable funding for housing purchases.  As FNMA (2019b) outlines, a dearth of financing options caused a crisis during that period, where banks did not have the capital needed to lend for residential home purchases.  Through the 1940s and 1950s, FNMA funded banks providing home loans to members of the military returning from the war, as well as the housing boom that benefitted the middle class.  By 1968, Congress determined that FNMA should change in structure, and at that time FNMA became a private shareholder-owned corporation, with the charter being issued by Congress.  This meant that the organization was no longer funded by the federal budget, and financing was funded through the issuance of stocks and bonds.  By the 1980s, mortgage-backed securities started being issued, and FNMA utilized these to provide additional funding for affordable housing.  When the global economic recession hit, FNMA was placed into federal conservatorship but continued to provide financing to the residential home market.  By 2012, FNMA had returned to profitability, and in 2014, they had paid $5 billion more in Federal dividends than they had taken out.

According to the Associated Press (2018), FNMA is not tax exempt, and the recent changes to the tax laws caused the federally-controlled corporation to experience a $6.5 billion loss.  FNMA is currently led by interim CEO, Hugh R. Frater (FNMA, 2018b).  The organization is in the residential property lending business.  The size of FNMA is reported in their annual book of business, which was just over $3.2 billion in November of 2018 ( Fannie Mae, 2018c).  As Connett (2018) explains, FNMA does not issue direct loans, but rather purchases or guarantees them on the secondary market.  This creates more liquidity for lenders such as credit unions, thrifts, and banks, who can then underwrite or fund more loans.

Mission, Vision, Values, and Goals

The mission of FNMA is to provide affordability, liquidity, and stability to the U.S. housing market (FNMA, 2011).  This mission statement is consistent with the actions and activities of the organization since its’ inception until today.  As FNMA (2011) outlines, this has informed the organization’s key decisions since its’ inception.  Even though FNMA was hit hard by the recession, causing them to need to be taken into conservatorship by the Federal Government, they have persisted in their vision to preserve homeownership, continuing to provide funding to the mortgage market after the worldwide recession, and working to help over 700,000 homeowners struggling to pay home loans during 2009 and 2010 to retain their homes, which has stabilized the neighborhoods, home prices, and housing markets in their area.  As another key part of the housing market, the rental market has also benefitted from the work of FNMA, with the organization providing $37 billion in debt financing for this market during 2009 and 2010, with between 87-91% of these housing units falling within the criteria of being considered “affordable housing” for their marketplaces.

The vision of FNMA is to be “America’s most valued housing partner” (Fannie Mae, 2019a).  This vision is well-aligned with the organization’s mission statement.  FNMA does much to assure that their vision is widely understood and accepted within the organization.  For example, the statement of vision in the opening of this paragraph is the first thing that prospective employees of FNMA see on the careers page.  In FNMA’s (Fannie Mae, 2018a) Code of Conduct, all values and behaviors are centered around this mission.  Within the code, values such as valuing people and their communities, serving their partners, doing things right, and leading the market are clearly articulated values that serve the central vision and mission of the organization.  All goals are expected to work towards the organizational mission and vision.

Strategy and Objectives

The unique situation of FNMA being in Federal conservatorship has influenced the strategy of the organization, though, in reality, the central components of the strategy are still well-aligned with the mission and values of the organization.  Organizational strategy and objectives are managed by a balanced scorecard approach.  As Dess, Lumpkin, Eisner, and McNamara (2012) outline, the balanced scorecard allows an organization to measure their performance from four central points of view: the customer, financial, innovation, and internal.  The balanced scorecard is considered “balanced” because it considers all of these elements then place them into measurable objectives.  After it was introduced, by 2004, 80 percent of large U.S. companies were using the balanced scorecard, but since then, usage has dropped (Hillstrom, n.d.).  McLellan (2014) reported that the use of the balanced scorecard was the 25th most used management accounting practice among 40 different management approaches. 

In the case of FNMA, because of the conservatorship, the setting of objectives and organizational strategy through the balanced scorecard has been delegated to the Federal Housing Finance Agency (FHFA; 2019).  The FHFA (2019) set the following priorities for Fannie Mae and the other agencies it supervises, including: maintaining credit availability and foreclosure prevention to foster efficient and liquid housing finance markets (40%), decreasing the risk to taxpayers by increasing the use of private capital in the mortgage, decreasing capital risk by enlarging the role of private capital in mortgage markets (30%), and creating new infrastructure for use by FNMA and the other enterprises, and adaptable for use by the secondary markets (30%).  These highly-specific goals and objectives are consistent with the mission and values of the organization and serve to facilitate its’ ability to provide financing for the residential housing market as well as to strengthen the home lending markets.

Strategy Types and Competitive Advantage

The overall strategy of FNMA within Porter's definitions is that of a business-level strategy.  As was mentioned in the previous section, because of the Congressional charter, FNMA is limited in the scope of business that they can become involved in.  Within this business-level strategy, FNMA has what Porter referred to as a focus strategy or niche strategy.  As Tanwar (2013) explains, in a focused strategy, an organization focuses on a few select targeted markets.  By focusing marketing efforts on very narrow market segments, this allows FNMA to meet the needs of the target markets better.  Competitive advantage is thus gained through effectiveness rather than efficiency. 

While FNMA may not be the only funder of fixed-rate mortgages, they certainly are the largest.  As Connett (2018) explains, FNMA and the complementary Federal Home Loan Mortgage Corporation (Freddie Mac), are responsible for the majority of mortgages that are purchased on the secondary market.  FNMA has been able to command such a large portion of the fixed-rate mortgage market because of their unique position in the marketplace, which gives them an unrivaled advantage in the credit marketplace.

As Fannie Mae (2011) outlines, one of the key advantages that they have is that they do not have to rely on traditional investors.  As they note, when economic times tend to become uncertain, investors who have tended to finance mortgages leave the marketplace.  This is because the investors that support them are uncertain of whether or not their investments in the mortgages being funded will be successful.  When the market collapse happened in 2008, FNMA was affected because they purchased mortgages that were sold to them under false pretenses.  Once the ground came out from under those mortgages, FNMA was saddled with an inventory of many mortgages that were in default and in danger of foreclosure.

The unique nature of FNMA permitted the organization to continue to provide needed services during this critical time.  As the Federal Housing Finance Agency (2019) outlined after the federal government bailed FNMA and Freddie Mac out of the financial situation they found themselves in after the housing market collapse, the federal government set specific criteria in a balanced scorecard that the agencies were expected to meet.  In addition to stabilizing the mortgage lending environment, FNMA was expected to increase the role of private capital in mortgage financing.  This has been accomplished through stabilizing homeowners who were previously in foreclosure through the HARP program being moved into streamlined refinance programs.  By stabilizing existing homeowners in place, this had the effect of providing increased dependability in the housing markets where such loans were provided, increasing the value of homes in the entire neighborhoods, and turning around situations where multiple losses could have been experienced.

Because of the dependability of FNMA in good times and bad, this has made FNMA the go-to repurchase of mortgages for many agencies, including banks, credit unions, thrifts, and other lending agencies.  In order to run their businesses with predictability, such financial organizations must have a dependable source of financing to repurchase the mortgages that they lend funds for.  This provides increased liquidity which their shareholders (for commercial entities) or member-owners (for credit unions) rely upon.  If a bank, thrift, or credit union had to rely upon commercial lenders or investors, who could leave the market at any point and time, this could lead to chaotic conditions for them, where they could be caught lending out capital that they could not recoup through the sale of their mortgages.  Because FNMA, through the backing of the Federal government, has proved to be a consistent source of mortgage liquidity, they have created a position that private lenders cannot compete with.

Organizational Size and Structure

Due to the unique situation of FNMA, the organizational structure has experienced some changes that are out of the norm for a business of this type.  Because FNMA is federally-chartered, and because they were taken into conservatorship by the Federal Housing Finance Agency (FHFA), FNMA has been executing specific mandates handed down by the FHFA.  According to the FHFA (2019), specific mandates that FNMA was to carry out include maintaining foreclosure prevention activities in order to encourage a liquid and resilient national housing finance market.  This objective makes up 40% of their scorecard, which outlines the metrics against which the agencies’ performance will be measured.  Other objectives include creating infrastructure for other organizations to perform in the secondary market in the future and increasing external investment through private capital for the mortgage market.

(Figure 1 omitted for preview. Available via Download). 

These mandates have created specific demands upon the organization which has been reflected in the organization size.  Figure 1 illustrates the total book of the mortgage business, as well as the total number of loan workout activity that the agency has had to be active in.  Loan workout activity consists of the work that FNMA has had to do in order to help homeowners stabilize their situation and prevent foreclosure.  The activity of helping homeowners to avoid foreclosure is a particularly resource-intensive process that requires more man-hours to perform.  As a result, when loan workout activities were a larger portion of their business, FNMA had to respond by having an increased staffing level to meet the needs.  This can be seen in the employee levels from 2014-2018 as illustrated in Figure 2.

(Figure 2 omitted for preview. Available via Download). 

As Figure 1 illustrates, the amount of Loan Workout Activity has been steadily declining, hitting its’ lowest point in 2018.  At the same time, the amount of loan activity as reflected in the total mortgage book of business has been steadily increasing.  As a result, the organization size was shrinking to reflect the decreased manpower levels to support Loan Workout Activities, but the total book of business of mortgage activities precipitated an increase in manpower for the first time in 2017.  As Dess et al. (2012) outlined, service, marketing and sales, and operations are key components of any organization’s primary business activities.  FNMA has demonstrated that they are adjusting their organizational size in order to meet the primary business needs while keeping an eye on expenditures at the same time.

As the organizational chart presented by The Official Board (2018) illustrates, Fannie Mae is organized around functional groupings which include common business functions such as HR and IT, as well as major business functions such as risk management and their main mortgage business.  This allows the organization to respond rapidly to needs within these organizational silos.  

Because of the situation with their conservatorship, FNMA is somewhat restricted in the makeup and nature of their board of directors.  For example, unlike other publicly-held organizations, shareholders are not entitled to vote for members of the board of directors (FNMA, 2018b).  As FNMA (2018a) outlines, through the conservatorship arrangement, their sole fiduciary responsibility is to the FHFA, their conservator.  The board of directors reviews the risk landscape and determines policies and procedures that will enable the organization to meet the mandates set by the FHFA as well as procedures and processes that will facilitate their primary missions, values, goals, and objectives.  By helping the organization to remain highly liquid, attracting more external investors, and having sound financial policies in place, this enables the organization to continue to be the primary source of mortgage liquidity in the United States. 

As has been discussed at length in this situation audit, central to the MVGO of FNMA is to provide liquidity to the markets.  While FNMA does have the backing of the U.S. Treasury, lawmakers, are justifiably concerned about the increasing amount of exposure that the federal government has to future losses in the market.  As Pozen and Pfannenstiel (2018) explain before the housing meltdown hit in 2008, the federal government backed only 35% of home mortgages, but since that time, the number has soared to over 70% of home mortgages.  The organizational structure has worked to increase private investment, slowly shifting this risk away from the federal government to private investors.  This secures FNMA’s ability to remain highly liquid and be able to continue as a source of liquidity for the mortgage market.

Critical Resources

In order to sustain a competitive advantage, FNMA must make the best use of the resources that they have at their access.  Resource-based theory, according to Dess et al. (2012), contends that firms need to manage resources that are both tangible and intangible in nature, which they combine with their unique capabilities to create and sustain a competitive advantage.  Under the tangible resource category, assets such as financial assets, physical assets, technological assets, and organizational assets are included.   Regarding intangible resources, these include human resources, innovation and creativity through change, and reputation.  One of the reasons that FNMA was able to weather the economic storm that occurred after the housing meltdown during the last recession was its unique relationship with the United States Government.

FNMA was created initially to provide a market and financing so that individuals could purchase homes.  When it was first formed, the funding came from the United States Treasury, but by the 1960s, FNMA was re-established as a private organization that was self-supporting.  Because the mission of home financing and home affordability is so intrinsically tied to the economic well-being of this country, the failure of FNMA is not an option.  Thus, as FNMA (2018b) outlines, when FNMA became saddled with mortgages that were underwater and posted a loss, the federal government stepped in and took FNMA and Freddie Mac into conservatorship.  This enabled FNMA to access funds from the U.S. Treasury, enabling them not only to continue lending to new prospective homeowners but also to help existing homeowners that were facing foreclosure to be able to refinance their homes so that they could stay in them when commercial lending was not available for that purpose.  This unique access to funding is one of the major resources that FNMA has at their access that gives them a huge competitive advantage over other purchasers of mortgage equity.  Because of the tremendous experience that FNMA has, they also take the lead in creating the systems that lenders can use to access mortgage equity.  This linkage gives FNMA the ‘inside track’ on how lenders will use the system and allows FNMA to tailor their offerings and shape the systems in the way that will best suit their customers, giving them a tremendous competitive advantage.

A huge resource that falls under the intangible resource column that FNMA has is their human resources.  As FNMA (2018b) reported in their annual report, their “business processes are highly dependent on the talents and efforts of [their] senior executives and other employees” (p. 35).  Because of limitations in compensation, this could become a problem if critical staff members were to leave the organization for better-paying jobs elsewhere, such as at competing financial firms.

The value of the human resources assets at FNMA cannot be overemphasized.  The work that FNMA does is highly complex and heavily regulated.  The work done at FNMA requires many highly-qualified individuals.  The current situation with FNMA is that the conservatorship agreement that they are under prohibits them from offering specialized types of compensation that are common in the financial industry.  These include performance bonuses, golden parachutes, and equity-based compensation packages.  In addition, because of the uncertainty of what Congress might do with regards to housing finance reform, there is a possibility that Congress may decide to wind down FNMA or restructure it, which creates another area of uncertainty that makes recruiting top talent challenging.  

The human resources issue becomes especially apparent at the top management levels.  The top management at FNMA is tasked with the responsibility to establish the policies and design the directives that permit the organization to meet the objectives established by their conservator, the FHFA.  As FNMA (2018b) reports, if there were to be major turnover in upper management, this could create a situation where turnover in key management positions could cause problems as the new management personnel needs to integrate into the existing management structure.  Such delays and challenges associated with them could interfere with FNMAs ability to manage their business effectively and could ultimately interrupt FNMAs implementation of the current strategic initiatives established for them by the FHFA.

Another resource that FNMA has is that they have a large number of employees that are centered primarily in Washington, D.C. and Dallas, Texas.  Having large groups of employees clustered in this fashion reduces travel expenses and takes advantage of key resources which would have to be much more dispersed if FNMA staff were located at many locations rather than primarily at two locations.  This centralization of employees provides an operational advantage.

Human resources truly are the most important resource at FNMA.  FNMA is a service organization.  The theory of path dependency explains why human resources at FNMA are such a unique asset.  As Dess et al. (2012) explain, path dependency is a resource or set of resources that have been developed through a unique set of circumstances that cannot be easily replicated.  Through the experience of helping homeowners through the foreclosure crisis, FNMA has gained particular expertise in the area of home financing that no amount of training or research could exactly duplicate.  This puts the human resources who were involved in this process at a very high value because the experience and knowledge that they have could have only come from the unique experiences that they gained as the result of helping so many homeowners save their homes from foreclosure.

Leadership, Governance, and Management

Management and leadership styles can do much to contribute to the success or failure in reaching the goals and objectives of the organization.  Few organizations have as much contact with their customers as FNMA does.  For this reason, David Benson (2017), president and CFO of FNMA explains that the company approaches their need to have a high customer focus by utilizing lean management principles.  The management approach utilized by FNMA includes high transparency, collaboration, and customer-focused actions designed to make the organization more effective in meeting the needs of its stakeholders.  Rotter et al. (2018) note that there are wide variances in descriptions of lean management, and there is no widely-accepted definition.  

The operating definition they note that is most common states that lean management is “an integrated socio-technical system whose main objective is to eliminate waste by concurrently reducing or minimizing supplier, customer, and internal variability” (Rotter et al., 2018, p. 3).  Applying this definition of lean management to FNMA, it appears that the effort to apply lean management principles is oriented towards making a more consistent experience for the customers and simplifying communications between employees at FNMA.  This is consistent with the company vision of wishing to be America’s most valued housing partner.

Management control systems (MCS) are put in place in order to measure organizational performance.  As Siska (2015) explains, MCS is generally defined as “the process by which managers assure that resources are obtained and used effectively and efficiently in the accomplishment of the organization’s objectives” (p. 142).  This is accomplished through the execution of FNMA’s “Way of Working management system,” which measures how the organization uses human resources to meet customer needs.  This is a part of FNMA’s continuous improvement efforts which have been taking place over several years (FNMA, 2018b).  The reason for using this management system was to make FNMA more competitive and responsive to changing market conditions.

From the time that FNMA went into conservatorship until now, it has emerged from a point where it had to be bailed out to now, where FNMA has generated a consistent profit.  In fact, between the start of the crisis, when FNMA went into conservatorship, FNMA made two draws from the Treasury for a total of $116.1 billion and had contributed $154.4 billion to the Treasury (FNMA, 2018b).  This has happened due to prudent organizational leadership being applied through the top.  As FNMA (2018b) outlined, considerable expertise and judgment are needed in creating risk models that are inherently judgment calls.  The organizational leadership team that has been assembled to direct FNMA has demonstrated by their strong business controls and return of profits to the Treasury that they are carrying out these responsibilities effectively.

While corporate governance is an important aspect of strategic control of a business, FNMA is faced with unique challenges in this area.  As Dess et al. (2012) outline, corporate governance is defined as “the relationship among various participants in determining the direction and performance of corporations” (p. 14).  The various participants indicated here are the shareholders, management, and board of directors.  Because of the conservatorship, the FHLA has ceded very limited rights and responsibilities to the FNMA Board of Directors, which they must execute under considerable scrutiny.  Still, despite these limitations, and despite considerable limitations in tools such as compensation packages and rewards, the Board has managed to return FNMA to profitability, demonstrating that they are good stewards of corporate governance.

Strengths and Weaknesses

As Dess et al. (2012) outline, the strengths and weaknesses components of the SWOT analysis refer mainly to the internal conditions of a firm.  This analysis shows areas where the organization excels in comparison with other competitors, and where the organization may be lacking.  The general idea behind conducting a SWOT analysis is that an organization must build on its strengths, and either remedy their weaknesses or find a way to work around them.

Clearly, one of the major strengths of FNMA is its’ relationship with the Federal government.  At a time when private capital dried up, and when FNMA was saddled with huge losses based on bad loans that had been sold to them, the Federal government took over and provided the capital needed so that the organization could continue.  No private lending organization has had that level of access to public funding, giving FNMA a unique competitive advantage.  It is exactly those advantages that allowed FNMA to soar from carrying only 35% of mortgages before the housing meltdown to over 70% after when other lenders left the market in droves.

A major weakness of FNMA is the fact that it is in conservatorship.  As FNMA (2018b) outlined, the terms of the conservatorship have put considerable limits on the compensation that FNMA can offer to their directors and to their employees.  For example, while under conservatorship, FNMA cannot offer any bonuses to their directors.  Compensation for the CEO is limited to $600,000 while the firm is in conservatorship.  Also, due to the rules of the conservatorship, FNMA may not offer any equity-based compensation to their employees.  This puts FNMA at a competitive disadvantage, as high compensation, bonuses, and equity-based compensation are all commonly offered by organizations in the financial industry to attract key talent, putting FNMA at a competitive disadvantage.

Learning and Change

Despite the limitations that being in conservatorship has placed on FNMA, the organization has demonstrated remarkable resilience and capacity to learn and change.  The organization has been engaged in a multi-year process to adopt the “Way of Working” program.  President and CFO David Benson (2017) estimates that it will require somewhere between three and four years for most of the company to complete the program.  As a part of this program, the emphasis has been on accountability and tracking, with metrics that allow the organization to track its success in achieving progress.  Company leaders, from the top down, have met with customers to gain a better understanding of their needs.  Through this process, FNMA has been able to determine which capabilities customers value, and which ones they do not.

A key way to measure an organization’s ability to learn and change is to measure the level of those developmental changes against clearly-defined metrics.  As Benson (2017) explains, one of the metrics that they measure is the percentage of customer request that is resolved within an agreed-upon time period.  The company also utilizes the Net Promoter score to determine customer satisfaction.  The Net Promoter score is an index of customer satisfaction wherein customers indicate how likely they are to recommend a company to others.  When the company started the Way of Working program, their Net Promoter score was relatively low, however since the program has been implemented, the scores have been consistently improving, demonstrating that customer responsiveness has improved as a result of the change program.  Each of the business units has its own metrics by which progress is measured.  Upper management works with the individual business units to help them to identify short- and long-term goals as well as the metrics needed to measure them.  The focus within the business is on not only executing new programs but measuring them and assuring that they align with the corporate strategic plan.

Conclusions and Recommendations

Based on the observations noted in this situation audit, it is clear that FNMA is doing a good job amidst the challenging situation of being in conservatorship.  The following areas have been noted in this report:

• FNMA has done well in getting their financial house into order, such that they have returned not only all that was borrowed but a profit to the Treasury.

• Despite financial limitations on compensation, FNMA has attracted a highly-qualified board which has been able to turn the organization around.

• The Way of Working program has shown clear benefits, increasing the level of customer satisfaction even in a limited time period.

The following activities are recommended to continue FNMAs success:

• Continue the Way of Working program so that everyone in the company can go through the program.

• Find unique ways to “reward” employees that raise satisfaction in the absence of the ability to provide traditional financial compensation packages.

• Continue to find ways to bring in outside capital to reduce risks to taxpayers.

Based on the findings in this report, the upper management and management style of the senior leadership has demonstrated that they are capable not only of turning the company around but making it even stronger after conservatorship.  By continuing the course of improvement through the Way of Working program, and by finding innovative means of increasing employee satisfaction, FNMA will be well-positioned to continue to be healthy and hopefully will demonstrate that they are capable of operating once again as an independent organization as they have been for much of their history.

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