“…2 Furthermore, these estimates were to be updated annually to reflect information on the actual and expected program performance. However, a growing literature contends that the FCRA underestimates the true costs associated with these programs and that a "fair value approach" offers a better metric for evaluating the costs that federal guarantees impose on taxpayers (see, for example, Congressional Budget Office [2012]; Lucas [2014a,b]; Hanson, Scharfstein, and Sunderam [2016]; Kelly, Lustig, and Van Nieuwerburgh [2016]; Lucas, [2012Lucas, [ , 2016; and Heaton, Lucas, and McDonald [2010]). 3 In general, the distinction between the FCRA and fair value methods rests on the choice of the discount rate used in determining the present values of the programs.…”