SIFMA provides comments to the Board of Governors of the Federal Reserve System, and the U.S. Departments of Treasury and Housing and Urban Development sharing serious concerns regarding the proposed use of eminent domain by San Bernardino County, California, and possibly other municipalities, to seize mortgage loans held in private-label mortgage-backed securities (MBS). Legal experts, including SIFMA’s counsel, former Solicitor General Walter Dellinger, believe this use of eminent domain to be unconstitutional, among numerous other legal disabilities.