Custody and Ownership Analysis of FNMA and FMCC Argentine Depositary Certificates

Combined Ownership Potential: CEDEARs and Institutional Holdings

Simplified Fannie Mae and Freddie Mac CEDEAR Analysis at B.Y.M.A.

• Both tickers are extremely illiquid on the public market, with most months showing zero reported trades.
• Volume spikes are synchronized, reacting to the same U.S. housing finance reform speculation, court rulings, and Argentine peso devaluation driving general CEDEAR demand.
• The 2013-2014 rally period dominates the lifetime trading activity for both instruments.
• This data suggests that the bulk of CEDEARs are likely acquired via direct block trades with Banco Comafi (OTC) rather than through open market operations on the BYMA.

Since September 2008, occasional events in the United States have briefly revived trading activity in the Fannie Mae and Freddie Mac CEDEARs on the B.Y.M.A. exchange in Buenos Aires. However, liquidity has remained extremely limited, with the last period of meaningful volume occurring in 2014.

Looking ahead, there is renewed certainty surrounding a potential public listing and the resumption of dividends to common stockholders-moves expected to create value for both shareholders and the U.S. government, which holds warrants for up to 79.9% of FNMA and FMCC.

It's important to note that these CEDEARs have been effectively frozen since October 2019. A local political event-not U.S. market developments-caused the already low trading volume to drop to zero for years. This coincided with the defeat of President Mauricio Macri and the return of the Peronists to power. In such an environment, investors seeking CEDEAR exposure tend to favor U.S.-listed companies with less speculative outlooks.

While certainty about these enterprises' futures has historically driven significant price appreciation in the U.S. OTC Markets-where the underlying Fannie Mae and Freddie Mac shares trade-no such momentum has been seen in Argentina. In fact, there has been no volume for FMCC.BA since October 2019, the same month FNMA.BA last traded. The final recorded transaction for FMCC.BA was a modest 2,500 CEDEARS on October 3, 2019.

In Argentina, it's generally not essential to revisit the last trade during such a long stretch of currency devaluations and shifting administrations-but it's worth noting for context. The final trade that kept the peso aligned with FMCC.BA's prior day closing price occurred on February 26, 2016, when 2,100 shares changed hands. The price then "leaped" to 20.95 ARS from the previous day's level due to a prolonged period of zero volume. This followed President Mauricio Macri's December 2015 decision to lift strict currency controls that had propped up the peso, triggering an immediate 35% devaluation and a total decline of about 55% over the following months.

Fast forward to October 2019: as elections approached and momentum shifted toward the Peronists reclaiming power, holders of CEDEARs began selling. This sell-off was unrelated to the U.S. news cycle surrounding the potential end of Conservatorship. In the U.S., President Trump had made notable moves in 2019-winning a court case to remove FHFA Director Mel Watt, appointing Mark Calabria, and signaling potential recapitalization of the now cash-rich Fannie Mae and Freddie Mac.

For Argentines, hedging against peso devaluation-regardless of which politically motivated president is in office-typically means moving into top-performing U.S. companies, with over 350 CEDEARs available. The likely scenario here is that the same investor chose to sell FNMA.BA and FMCC.BA, anticipating that pro-business President Macri would not secure another term, even with President Trump in office. It was probably seen as an opportunity to shift pesos into a less speculative investment given Argentina's domestic situation.

Support for pro-business policies remained strong, but after Macri's loss-despite receiving 40.4% of the vote-many investors redirected their capital elsewhere.

Investors understood that with the Peronists maintaining tight currency controls, persistent subsidy issues, and high inflation, it made little sense to sit on CEDEAR positions and wait. It took the renewed certainty at the start of President Trump's second term to prompt Argentines to move pesos into CEDEARs of these enterprises-mirroring the substantial price appreciation of the underlying common shares listed on the U.S. OTC Markets.

Liquidity in these CEDEARs is limited, but not because of a lack of interest. The upcoming public offering is already oversubscribed, and positive news is widespread. The administration has repeatedly reaffirmed its intention to bring the shares public in 2025. In the U.S., liquidity is tight, raising the question of who else is holding these shares-especially given that reported institutional and mutual fund stakes don't tell the full story. If retail investors alone were responsible for such low volume, large block trades would be virtually impossible despite the certainty surrounding what some Executive Branch members have called "the biggest IPO in history," even larger than Aramco, as Secretary Lutnick recently stated on CNBC.

So why are Argentines struggling to access this trade? Even with strong U.S.-Argentina relations under Presidents Trump and Milei-a relationship dating back to Trump's congratulatory video to President-elect Milei in November 2023, and Milei's historic attendance as one of only two foreign heads of state at a U.S. Presidential Inauguration-the sentiment to move pesos into FNMA.BA and FMCC.BA CEDEARS exists. Yet, trading activity has only appeared in FNMA.BA, with sharp price jumps for small share amounts. Freddie Mac's CEDEAR, FMCC.BA, remains inactive.

Positive U.S. developments began driving FNMA.BA volume after Bessent's interview outlining his plans for the government stake and the sovereign wealth fund assigned to him by Executive Order on February 3, 2025, alongside Secretary of Commerce Howard Lutnick's remarks on the March 19, 2025 All-In Podcast. Still, FMCC.BA has stayed frozen.

Since March 2025, several events have fueled FNMA.BA's momentum: Bessent's endorsement of a Temasek-style sovereign wealth fund model; Truth Social posts from the President in May and August 2025; and Lutnick's September 2025 CNBC interview discussing a rumored 3-6% IPO stake sale from the government's warrants, signaling an end to Conservatorship. This plan to return value to the American people also points toward dividends for common shareholders. Lutnick, known for moving markets, has now been credited with driving value upward-contrasting earlier media criticism over "tariff" comments in spring 2025. Those tariffs have since generated hundreds of billions of dollars for the U.S., alongside trillions in foreign investment commitments from companies eager to operate in the American consumer market.

In Argentina, whether you're seeking a private placement off the B.Y.M.A. or simply trying to buy CEDEARS of FMCC.BA on the exchange, the reality is the same: zero trading volume since October 3, 2019. The creation of new CEDEARS for Freddie Mac shares-custodied in the United States at BNY Mellon-has effectively stopped.

How did Argentina come to hold so many FMCC shares in the U.S.? The answer is straightforward. President Trump entered his second term prepared to advance his agenda, and President Milei-backed by billionaire and former President Macri-was equally ready. The use of CEDEARs and public-private partnerships, facilitated through discreet private placements via Banco Comafi and local brokerages, was a calculated strategic move.

By 2023, ARS/USD inflation was spiraling out of control. For investors, it was the perfect moment to back Milei-much like John Paulson once backed Trump-by taking positions in key assets. The opportunity became even more compelling after President-elect Trump emerged from the November 5, 2024 election alive and politically strong. With Milei as a pro-Trump candidate enjoying massive public support, and Macri's pro-business influence behind him, it was an ideal time to convert pesos into stakes in Fannie Mae and Freddie Mac.

These positions, initially taken by private citizens before Milei's victory, began to rise from the January 2023 lows of the underlying U.S. shares. Once Milei assumed office, the strategy expanded to include a government stake-though kept less public than Trump's high-profile investments in MP Materials or Intel. This discretion was deliberate: Trump needed to secure election victory and the backing of sovereign wealth funds, as reported by the Wall Street Journal a year earlier, when Larry Kudlow and Trump's envoys pitched the idea to such funds.

What was never publicly stated is that Argentina had been quietly accumulating privately placed CEDEARs-both before and after Milei's election-in a public-private structure designed to channel much-needed pension, provincial, and peso inflows into perpetual dollar returns. The timing was perfect: maximum issuance limits could be used to express confidence in Milei and Trump in successive years, reshaping capitalism in both countries for the benefit of private citizens burdened by past government mismanagement.

The sovereign wealth fund holding these assets at BNY Mellon-a structure Trump favors-offers Argentines protection from future domestic government interference, while the U.S. government has no claim over the $53 trillion in assets under custody since BNY Mellon's 2007 pivot to custodial services. With 500 trillion shares custodied, at least 499 million represent public-private Argentine investments capable of delivering untaxed dollar returns indefinitely in Milei's deregulated, "sin cepo" (no currency controls) banking environment.

The value of the Fannie Mae and Freddie Mac holdings alone could cover all of Argentina's outstanding international loans through dividends. The currency mechanism itself serves as a secure bridge-an entry point with no foreseeable exit-for the strategic economic pact between Argentina and the United States. This pact blends private placement on one side with BNY Mellon's custodial role on the other, coordinated legally with Milei's backers before his election and his government afterward.

This is the backdrop to Freddie Mac's situation-and why liquidity in FMCC.BA on the B.Y.M.A. is nonexistent. As Argentina's October midterm elections approach, Milei is poised for President Trump to announce a landmark trade deal under "TMAP," signaling a deep cross-border alignment between two governments whose citizens have voted decisively for capitalism and opportunity.

Seriously - 500,000,000 shares of Freddie Mac ordinary, common stock "FMCC" is in the custodial account at BNY Mellon and the main sovereign investor in the U.S. taxpayer's long term interests in rapidly paying off debt via dividends and growth. Argentina and Banco Comafi S.A. itself has long issued their mortgages denominated in USD. Perhaps expansion into Argentina is not off the table for the near and long term plans for the two perpetually profitable cash creating enterprises at the heart of the American - and as we saw in 2008 but TenThousandX® believes for different reasons than most Americans looking outside in - World economy. When it does well - the world does well too.

What would happen should someone want to place an order with their broker in Argentina if not on the B.Y.M.A.? Let's take a look at how both would be denied their CEDEAR issuance request relatively fast from the Buenos Aires side of this one way relationship, that is set to return the dollars and then far more dollars that Argentine's desperately need for credit extension and growth to begin and also sustain itself from the heart of the American economic engine:

Here's how the limit impacts the steps previously provided for CEDEARs that have hit their maximum limit:

In short, the market for FMCC.BA shifts entirely to a secondary market. Buyers can only acquire what sellers are willing to offer from the fixed pool of 500,000,000 existing CEDEARS. This creates a "closed system" where the price is driven exclusively by the supply and demand within Argentina, which can lead to the CEDEAR's price decoupling from the underlying U.S. share price.

Banco Comafi's Aware and Prepared for Credit to Expand in Argentina¹⁶

This alone is reason enough-using logic and the processes outlined in this report-to ask: why one, but not the other? Especially when there are still 200,000,000 additional CEDEARS authorized for issuance on the B.Y.M.A. after the custodian at BNY Mellon has already received the underlying shares.

The delivery of FMCC shares to BNY Mellon's custodial side of the soon-to-be-revealed Argentine "fund" is complete. It supports both the small retail float-just over 1.1 million in total volume for FMCC.BA over 17 years and the much larger 499+ million share stake that Argentina strategically secured. This position was acquired fairly, with bets placed on a Trump election victory two years before most in the United States had even heard of Javier Milei. In that sense, the timing hardly mattered.

The limited volume in FNMA.BA follows a similar pattern. In early 2024, TenThousandX® observed in its own brokerage account a post-market flash of a massive position-well beyond Pershing's stake in FNMA-held by BNY Mellon's custodial service, the largest "institutional" holder. Such positions are entirely possible to see when end-of-day share deliveries reach the custodian, regardless of whether the CEDEAR order and issuance occurred on the B.Y.Μ.Α.

This section is mostly-citation free for a reason, it's not theoretical.

We will leave it at that.