Congressional Justifications for 1998 Budget Estimates

Office of Federal Housing Enterprise Oversight
Salaries and Expenses

The Federal Housing Enterprises Financial Safety and Soundness Act of 1992, P.L. 102-550, Section 1313(a)], Title XIII of the Housing and Community Development Act of 1992, established the Office of Federal Housing Enterprise Oversight (OFHEO) as an independent office in the Department of Housing and Urban Development (HUD). The principal responsibility of the Office is to ensure that the two largest government sponsored enterprises (GSEs)--the Federal National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie Mac)--are adequately capitalized and operating in a financially safe and sound manner. The Act requires OFHEO to develop a stress test to determine risk-based capital requirements and to conduct other research and financial analysis necessary for effective regulatory oversight of the GSEs. OFHEO is also required by statute to conduct on-site, annual examinations at Fannie Mae and Freddie Mac to determine the condition of each Enterprise for the purpose of ensuring their financial safety and soundness.

The assets of the Enterprises have more than doubled in the past 4 years and continues to grow rapidly. At the end of 1996, Fannie Mae and Freddie Mac together managed the credit risk of nearly $1.5 trillion in mortgages and had over $1 trillion in mortgage-backed securities outstanding. This past year, their liabilities have grown by 16 percent, and their mortgages held in portfolio, where the risk is concentrated, have grown by 18 percent. The Enterprises' growth in both of these areas is expected to continue at nearly these rates in the foreseeable future.

To finance their growing portfolios, the Enterprises have expanded their global debt facilities to issue debt securities to international investors. At the same time, mortgage finance markets are undergoing major changes, including increased automation and consolidation. The Enterprises are also expanding the scope of their new housing finance activities. It is critical that OFHEO fully develop its capacity to assess risks and market conditions as they impact on the financial safety and soundness of Fannie Mae and Freddie Mac.

Appropriation Highlights

Although subject to the appropriations process, OFHEO is not funded with taxpayer dollars. Section 1316 of the Act authorizes the collection of annual assessments from Fannie Mae and Freddie Mac to cover OFHEO's annual operating costs to the extent appropriated. The following table summarizes the funding and staffing included in this request.

	Actual 1996	Estimate 1997	Request 1998	Increase + Decrease -
(Dollars in Thousands)
From Appropriation:
Budget Authority (Assessed to GSE's)	$14,895	$15,000	$16,312	+$812
Prior Year Recovery a/	311	...	...	...
Reimbursement Income b/	159	40	...	-40
Budgetary Resources.	15,365	15,540	16,312	+772
Total Obligations	14,937	15,540	16,312	+772
Unobligated Balance EOY c/	428	...	...	...
Outlays (Net) d/	16,020	15,540	16,312	+772
Full-Time Permanent Appointments, EOY	66	72	72	...
Full-Time Equivalent Employment	66	78	78	...

a/The $311,000 in 1996 represents the recovery of prior year funds obligated via a contract in fiscal year 1995 and reapportioned by OMB for reobligation in 1996.

b/The $159,000 in 1996 represents the Participating Agency Service Agreement (PASA) executed between OFHEO and the Agency for International Development (AID) in support of the US-Mexico Binational Commission's efforts to assist Mexico in its development of a secondary mortgage market. OMB apportioned this amount to OFHEO as reimbursable budget authority. AID extended its agreement with OFHEO for fiscal year 1997 and made available to OFHEO an additional $40,000.

c/The unobligated balance of $428,000 includes both assessment related funds and reimbursement funding from AID. The amount unobligated which applies to the assessment is $415,000. AID funds expire.

d/ The outlays for fiscal year 1996 exceed budget authority for fiscal year 1996 because the outlays represent expenditures from obligations incurred during fiscal year 1996 as well as prior years.

NOTE: Full-time permanent figures are estimates based on a calculation of the permanent positions made affordable by full-time equivalents with the personal services dollars as budgeted. They are not control numbers and may vary depending on conditions.

Summary of 1998 Budget Request

For fiscal year 1998, OFHEO requests $16.3 million, an increase of 5.2 percent over the fiscal year 1997 enacted budget of $15.5 million. This reflects a modest increase, now that start-up operations are completed.

For personnel, both the 78 FTEs and the 72 full-time permanent positions requested represent no change from the fiscal year 1997 levels.

The resources in this Budget request will permit OFHEO to proceed effectively in all facets of the regulatory agenda assigned by Congress. These include financial safety and soundness examinations of the Enterprises, ongoing development and implementation of the stress test model, and other financial, analytical and policy tools required for effective regulatory oversight. The secondary mortgage-market continues to evolve and increase in complexity. This request will enable OFHEO to continue to strengthen its institutional knowledge base, provide increased continuity of examiners, maintain the quality and timeliness of its activities, and continue to develop as an expert in the secondary mortgage market.

OFHEO's complex financial and regulatory mission requires specialized expertise, notably, the skills required to examine and analyze the business operations of the GSEs as well as related capital markets and mortgage market issues; and the ability to create, implement, maintain and enhance the stress test that determines risk-based capital standards for Fannie Mae and Freddie Mac. To function as an efficient and effective financial regulator and anticipate potential threats to taxpayers, OFHEO must have the capacity to anticipate and assess economic and market issues that could affect the GSEs. Additionally, OFHEO must be responsive to Congress as it relates to emerging issues that could affect the GSEs.

OFHEO is also requesting a small Reception and Representation (R&R) fund of $3,000. This fund is intended for use by the OFHEO Director in conducting official representation activities in connection with OFHEO's mission, particularly in conjunction with holding public hearings on the proposed rule for the risk-based capital regulation. This modest amount parallels the availability of R&R funds to all departments, and to many specific bureaus and independent agencies. Because OFHEO's funding and operations are distinct from those of HUD, OFHEO does not seek to participate in the Department's R&R fund, but is requesting its own.

The fiscal year 1998 Budget also proposes a technical change in the appropriations language to facilitate the full availability of the appropriation at the start of the fiscal year. Under the current language, OFHEO is restricted to obligating its budget authority based on the timing and amount of its collections from semi-annual assessments (by statute, October 1 and April 1 for the fiscal year). Because Federal agencies must obligate the full year's funds for certain activities at the start of the year (e.g., rent, software licenses, subscriptions), the current language puts unnecessary restrictions and administrative burdens on OFHEO's operations. The proposed change is similar to that enacted for other Federal agencies.

Funding

The following table summarizes obligations for this activity by object class.

	Actual 1996	Estimate 1997	Request 1998	Increase + Decrease -
(Dollars in Thousands)
Personal Services	$7,234	$9,119	$9,572	+453
Travel	133	237	336	+99
Transportation of Things	7	60	50	-10
Rent, Communication Utilities	1,781	1,804	2,006	+202
Printing and Reproduction	24	74	118	+44
Other Services	4,800	3,793	3,664	-129
Supplies and Material	406	255	270	+15
Furniture and Equipment	407	158	296	+138
Subtotal	14,792	15,500	16,312	+812
Reimbursement AID a/	145	40	...	-40
Total	14,937	15,540	16,312	+772

a/ In 1996, OFHEO also obligated $36,175 for travel and $109,263 for other services funded by the reimbursement agreement with AID. OFHEO had $159,000 apportioned for reimbursement and obligated more than $145,438. The amount unobligated was $13,562. These funds were contained in the fiscal years 1995 and 1996 appropriations for AID. Changes From Estimates Included in 1997 Budget.

As OFHEO has moved from a start-up operation to a more mature organization, its obligations have more closely matched its appropriations. In fiscal year 1995, OFHEO did not obligate $1.9 million of its $15.5 million appropriation. For fiscal year 1996, OFHEO had unobligated funds of only about $0.4 million.

As required by statute, OFHEO credits the current year's assessment of the GSEs with the amount of the assessment unobligated from the previous year. Consequently, OFHEO does not have an increase of funds available due in 1 year because of amounts carried forward from the previous year.

OFHEO obligated approximately $145,000 for expenses covered in its reimbursement agreement with AID leaving about $14,000 unobligated from the reimbursement agreement. These funds are not part of OFHEO's assessment and no credit to the Enterprises will result.

OFHEO requested $15.8 million for fiscal year 1997 and received $15.5 million in enacted budget authority. OFHEO is absorbing the budget cut by trimming other services and travel, as well as through a lapse in filling personnel vacancies.

Analysis of Increases and Decreases

	Current Estimate 1997	Request 1998
(Dollars in Thousands)
Prior-year obligations	$14,792	$15,500
Estimates for Personal Services	+1,885	+453
Change to Travel Costs	+104	+99
Change to Transportation of Things	+53	-10
Change to Rent, Communications and Utilities	+23	+202
Change to Printing and Reproduction	+50	+44
Change to Other Services	-1,007	-129
Change to Supplies and Materials	-151	+15
Change to Furniture and Equipment	-249	+138
Total Obligations	15,500	16,312

Explanation by Object Class

OFHEO's development requires the nearly continuous assessment of staffing and resource allocations as mission critical work evolves and as needs are refined. The total funding request in 1998 is $16.3 million. This represents a 5.2 percent increase over the 1997 estimate.

Personal Services. OFHEO's fiscal year 1998 Budget request is 5 percent more than the current estimate for fiscal year 1997. The increase is associated with additional costs attributed to hiring and retaining staff for very specialized, technical jobs in the mission areas. The type of skills required in examination, oversight, and financial modeling functions are highly marketable in the private sector. OFHEO has had difficulty recruiting and retaining staff in these areas. The Budget request contains funding for a full year for 78 FTEs.

OFHEO's personal services budget and its administration differs from most other Federal agencies' because OFHEO, by statute, is exempt from Title 5 pay and classification standards administered by the Office of Personnel Management and is required by statute to maintain compensation comparability with other Federal financial regulators. OFHEO has no automatic within-grade pay increases and does not give the annual cost of living increase approved for most Federal employees. OFHEO distributes performance-based merit increases as base pay increases and or lump sum payouts. The personal services budget increase includes a continuation of the standard federal benefits package and does not provide funding for additional benefits.

Also included in the fiscal year 1998 request are funds for a limited amount of support from intermittent experts. The request continues the cost-effective use of temporary appointments in lieu of contract support for positions that fill a temporary need at OFHEO. The Budget request continues funding for detailees during fiscal year 1998 for the examination and legal offices.

Travel. OFHEO is requesting a $99,000 (42 percent) increase in travel. The 1998 request supports travel associated with facilitating public hearings on the proposed risk-based capital regulation and presentation of the stress test in various industry forums. The request also supports travel to the Regional Offices of the Enterprises for examinations and for activities related to financial modeling and research. It also includes travel for intermittent experts and expenses associated with the temporary detail of examiners from o�hedera�eral financial regulators, whose duty stations may be outside the local area. The request supports continued participation of OFHEO staff in professional seminars and meetings which benefit mission related work and support activities.

Transportation of Things. OFHEO's fiscal year 1998 Budget request is nearly 17 percent lower than the fiscal year 1997 estimate. This reflects the assumption that OFHEO's need to relocate newly hired staff will diminish during fiscal year 1998. It also reflects a reduction in shipping charges for supplies and equipment.

Rent, Communications and Utilities. The $202,000, or 11.2 percent increase for fiscal year 1998 reflects an increase in the rental charges for the existing space OFHEO occupies, and additional charges for Internet access, telephone use, and copy machine rental.

Printing and Reproduction. OFHEO is projecting a 59 percent increase in this category. In 1998, OFHEO intends to publish several proposed and final rules. OFHEO also expects to publish technical and analytical studies, print manuals and handbooks to support operations, as well as publish OFHEO's Annual Report to Congress and quarterly House Price Index.

Other Services. Other services for 1998 reflects a decrease of $129,000 (3.4 percent) below the 1997 estimate. It continues to support specialized technical services associated with development of the risk-based capital stress test as well as on-going needs for specialized technical services associated with the maintenance of the computer system housing the stress test. This category includes costs for technical experts, on an as-needed basis, to support project-specific examination activities. It also includes contractual support for administrative activities for specialized needs and projects.

Supplies and Materials. This includes an increase of 5.8 percent. It represents the cost of office supplies for a full complement of staff and contractors on site, as well as subscriptions, computer supplies, standard software, and copier supplies.

Furniture and Equipment. While the 1998 request is 87 percent greater than 1997, the $138,000 requested are small. The 1998 request is 27 percent lower than the actual cost of furniture and equipment in fiscal year 1996. The 1998 Budget request represents modest replacement costs for information technology and a modest amount of new purchases, in contrast to the earlier costs of outfitting a new office. Equipment currently on-site will be 4- to 5-years old. In order to continue to make effective use of OFHEO's small staff, the Office plans to replace its equipment gradually on a 4-year cycle, and estimates that annual cost at $121,250. Each year's purchase is expected to be compatible with the existing system.

Staffing Summary

Scope of Activity

OFHEO functions as an independent office within HUD, responsible for regulation of Fannie Mae and Freddie Mac in matters of capital adequacy and financial safety and soundness. The Office is headed by the Director who is appointed by the President for a 5-year term and is responsible for the overall operation of OFHEO.

The Act requires OFHEO to develop a stress test to determine risk-based capital requirements and to conduct other research and financial analysis necessary for effective regulatory oversight of the GSEs.

OFHEO is also required by statute to conduct on-site, annual regulatory examinations at Fannie Mae and Freddie Mac to determine the condition of each Enterprise for the purpose of ensuring their financial safety and soundness. The examinations are designed to identify the overall risks in the business activities of the Enterprises, and to determine if those risks are being prudently managed, controlled, and monitored. Additional special examinations may be conducted as necessary, as determined by the Director.

Additionally, the Office is required to: issue regulations; report annually to Congress; determine quarterly capital levels; take needed enforcement actions; and prohibit excessive executive compensation at the Enterprises.

The Director has organized OFHEO into six offices:

a. Research, Analysis and Capital Standards.

b. Examination and Oversight.

Develops and maintains capability to examine Fannie Mae and Freddie Mac, including sophisticated expertise in capital markets, portfolio management, financial and regulatory accounting, and mortgage credit analysis. Conducts the annual examinations required by law of the two Enterprises and performs additional examinations as necessary, as determined by the Director.

c. Finance and Administration.

Ensures that the Office has the infrastructure to function independently and efficiently. Provides support services in human resources management, Budget formulation and execution, financial planning, contracting and purchasing, information resources management, internal controls management, travel, and related administrative support services.

d. General Counsel.

Supports OFHEO in carrying out its regulatory responsibilities. Develops regulations required by the Act, administers the Office's ethics program, and advises the Director and each office on legal issues. Provides advice on financial institution regulatory issues, corporate law principles, as well as on administrative and general law matters including federal contracting and procurement, personnel, and equal employment opportunity.

1. Congressional and Public Affairs. Ensures appropriate coordination and communication by OFHEO with the Congress for monitoring relevant developments and for analyzing and developing legislative proposals. Responds to congressional inquiries, and informs and educates members of Congress and their staffs about OFHEO activities. Serves as a Spokesperson for OFHEO. Responds to inquiries from the press, trade groups, and the public at large.

2. Chief Economist. Conducts research and policy analyses to assess and project the short- and long-term impact of issues and trends in the housing and mortgage finance industries on OFHEO's financial regulatory and supervisory responsibilities. Also, develops policy options and supporting analyses on a broad range of issues.

Work Load

1996 Accomplishments

Following are specific accomplishments during 1996.

Rulemaking



• Published the final minimum capital regulation for the Enterprises in July 1996 which defines necessary terms, sets forth the methodology for computing the Enterprises' minimum capital levels, establishes procedures for filing quarterly minimum capital reports, and establishes procedures for determining the quarterly capital classification of the Enterprises.
  
  

• Issued for public comment the first of two notices of proposed rulemaking (NPR) for the risk-based capital regulations in June, 1996. The NPR proposed the methodology to be used to determine the credit stress bench-mark loss experience--the basis for determining the extent of the credit losses during the stress test. It represents the worst regional mortgage loss experience over at least a 2-year period for an area of the country containing at least 5 percent of the population. The NPR also proposed the use of the OFHEO House Price Index (HPI) to estimate the changes over time in the values of single-family properties securing Enterprise mortgages.
  

  Research and Policy Analysis

• Completed key components of the risk-based capital stress test, including economic models to simulate single-family mortgage defaults and prepayments, computer programs that accurately simulate precise liability and non-mortgage derivative cashflows, and prototype software to translate Enterprises' cashflows into pro forma financial accounting statements.
• Made substantial progress on a number of stress test-related projects, including the development of economic models of multifamily mortgage defaults and prepayments, economic models of single-family and multifamily loss severity, models to simulate various Enterprise operating decisions (e.g., dividend payouts, new debt issuance), and models to simulate the consequences of mortgage insurance and other credit enhancements.
• Classified the Enterprises as adequately capitalized for the third and fourth quarter of 1995 and the first three quarters of 1996, according to statutory minimum capital standards.
• Initiated publication of the House Price Index (HPI), OFHEO's quarterly statistical index of national, state and regional changes in home prices.
• Completed an analysis at the request of Representative Richard Baker of the effect of a 600 basis point increase in interest rates over 18 months and other severe economic circumstances on the earnings and capital of the Enterprises. This analysis employed OFHEO's modeling and analytical tools that have been developed for the risk-based capital stress test, as well as the Enterprises' internal models.
• Made a full and complete report to Congress on OFHEO's activities and condition of the Enterprises.
• Completed development of a database of Enterprise mortgage loan data in a consistent form that gives OFHEO the ability to analyze the two Enterprises' portfolios while limiting the burden as much as possible consistent with receiving accurate and timely information.
• Undertook the following activities funded by AID: Supervised study projects on "The Role of Government in Secondary Mortgage Market Development" and "Management of Credit Risk in the Secondary Mortgage Market by Fannie Mae and Freddie Mac"; organized a seminar, staffed by experts, on the nuts and bolts of mortgage lending in the U.S.; and sponsored a paper on "Legal and Regulatory Obstacles to Securitization in Mexico."


Examination and Oversight

• Conducted and issued reports of examination, and met with boards of directors for Risk Management Examinations, including credit risk and interest rate risk components, of the Enterprises.
• Planned, scoped, staffed, and initiated field work for Business Risk Examinations, focusing on the single family business, of the Enterprises.
• Planned, conducted, and issued compliance reviews on flood insurance compliance of the Enterprises, in accordance with the National Flood Insurance Reform Act of 1994.
• Conducted Field work for examination on data integrity.
• Completed first draft of the Examination Handbook, including the role of examination, an evaluative scheme for examination ratings, and policies and procedures for examinations, to enhance the infrastructure of the Office.

• Developed and enhanced the monitoring and financial analysis functions of the Office.


Infrastructure

• Submitted Quarterly Reports to the HUD Secretary.

• After working with HUD to convert OFHEO's accounting activities to HUD's new system, OFHEO assessed its effectiveness. OFHEO entered a cross-servicing agreement with the Department of Veterans Affairs (VA), one of the Government Management Reform Act franchisers for financial management systems. OFHEO converted its financial accounting activities to the VA Financial Management System on October 1, 1996.

• Developed policies and procedures for OFHEO's operation as part of the competitive service rather than the excepted service.
• Submitted OFHEO's annual letter of assurance to the President and the Congress pursuant to the Federal Managers Financial Integrity Act (FMFIA).

B. 1997 Plan

OFHEO has identified the following strategic objectives for completion in 1997:

Rulemaking

• Begin interagency review process with OMB, Treasury, and HUD on the risk-based capital stress test that OFHEO plans to propose.

• Issuance of final regulation on release of information, which implements the provisions of the Freedom of Information Act.

• Issuance of proposed regulation establishing the Rules of Practice and Procedure related to the conduct of enforcement actions.

• Issuance of proposed regulation implementing the Privacy Act.


Research and Policy Analysis

• Continue quarterly classification of the capital adequacy of the Enterprises, applying final regulatory minimum capital standards.

• Continue quarterly publication of OFHEO's HPI, demonstrating changes in home prices for the nation, each state and the nine census regions.

• Take a full and complete report to Congress on OFHEO's activities and condition of the Enterprises.
• Complete development of a sophisticated "working" version of the Financial Simulation Model (FSM) and risk-based capital stress test to enable OFHEO to, among other things, conduct analyses of the sensitivity of capital levels to varying assumptions in the stress test.
• Review and analyze all comments on the first risk-based capital Notice of Proposed Rulemaking to enable OFHEO to address concerns raised by commenters in the final risk-based capital regulation.

• Continue to develop comprehensive Enterprise database to support both stress test development and off-site monitoring and analysis.

• Specify, design and construct a comprehensive data warehouse encompassing the existing mortgage database, that will house Enterprise data necessary to generate the starting positions for the stress test and to support off-site monitoring and financial analysis.
• Develop a comprehensive framework for determining the comparability of executive compensation and the reasonableness of any severance packages at the Enterprises.


Examination and Oversight

• Conduct and complete examination on data integrity.

• Conduct and complete Business Risk Examinations, focusing on the single-family business of the Enterprises.

• Plan, scope and conduct Business Risk Examinations, focusing on the multi-family business of the Enterprises.

• Prepare Risk Assessments of Enterprise information systems and technology and conduct Information Systems and Technology Examinations.

• Design, develop and implement an off-site monitoring system to supplement the "core" examinations and to ensure the identification of high priority safety and soundness issues.

• Publish the Examination Handbook to codify examination policies and procedures.


Infrastructure

• Complete conversion of OFHEO financial management activities to the VA-provided system. Complete validation and verification of conversion from HUD's administrative accounting system to the VA Financial Management System.

• Evaluate OFHEO's Performance Evaluation Management System.

• Continue to develop, implement and improve administrative systems and policies to support OFHEO's activities using the principles of the National Performance Review, the Government Performance and Results Act the Government Management Reform Act, and the Information Technology Management Reform Act.

• Strengthen OFHEO financial and administrative expertise to support OFHEO's evolving operations.

C. 1998 Goals

Rulemaking

• Publication of the second proposed regulation on risk-based capital setting forth the stress test for determining risk-based capital.

• Publication of proposed regulation implementing the Equal Access to Justice Act.

• Publication of proposed regulation implementing the prompt corrective action provisions of the 1992 Act.

• Publication of proposed regulation establishing the Rules of Practice and Procedure related to the conduct of enforcement actions.

• Publication of proposed regulation implementing the Debt Collection Act.

• Publication of final regulation implementing the Privacy Act.


Research and Policy Analysis

• Classify the capital adequacy of the Enterprises quarterly, applying final regulatory minimum capital standards.

• Continue quarterly publication of OFHEO's House Price Index.

• Make a full and produce report to Congress on OFHEO's activities and condition of the Enterprises.

• Review and analyze all comments on the second risk-based capital Notice of Proposed Rulemaking and undertake all follow-up work and or evaluation of alternatives necessary to complete a final risk-based capital regulation.

• Complete development of flexible reporting interface for the comprehensive Enterprise database to facilitate off-site monitoring and Enterprise analysis.

• Continue to monitor comparability of executive compensation at the Enterprises and determine the reasonableness of any severance packages.


Examination and Oversight

• Plan, scope and conduct Operations Risk Examinations of the Enterprises.

• Fully develop an Information Systems Technology Examination cycle. Ensure that the examination approach for information management and technology results in a comprehensive and integrated evaluation of the subject areas.

• Review and assess the core examinations (e.g., Corporate, Credit Risk Management, Business, and Operations). Validate the effectiveness of these discrete examinations or redefine/restructure the examination cycle to ensure a comprehensive assessment of safety and soundness.

• Design special studies that address high priority issues through the examination process and explore alternative, targeted approaches to focus on specific safety and soundness areas.

• Fully develop monitoring and financial analysis capabilities to ensure that the off-site surveillance function (e.g., staffing, analytics, databases) provides a comprehensive and timely assessment of Enterprise safety and soundness.


Infrastructure

• Continue to evaluate and improve the efficiency and effectiveness of financial and administrative programs and systems.

• Continue to provide administrative support services in a cost effective manner which also meet OFHEO's operating needs.
  
  

1. Summary of Staffing Requirements

All personnel in this office are assigned to Headquarters. OFHEO has no Field Offices. The FTE staff is as follows:

	Actual 1996	Estimate 1997	Request 1998	Increase + Decrease -
Full-time Permanent Positions	72	72	72	...
Full-time Permanent Positions Temporary, Term and Part-time Positions	9	8	7	-1
Full-time Permanent Positions Full-time equivalent	72	78	78	...


2. Summary of Staffing by Pay Level

The Director of OFHEO, through the Act, may appoint and fix compensation of the officers and employees of the Office without regard to Title 5, United States Code, relating to classification and General Schedule pay rates. OFHEO maintains comparability with Federal banking agencies, as required by Section 1315 of the Act. The Office has a lean, flat organizational structure staffed by highly-qualified senior individuals. The following chart depicts full-time permanent positions:



Pay band		Actual 1996	Estimate 1997	Request 1998
Level	Pay range
I	$15,876 - 26,4600	0	0	0
II	21,168 - 42,337	8	7	7
III	31,753 - 58,213	8	8	8
IV	42,337 - 79,381	5	5	5
V	52,921 - 105,842	22	21	21
VI	79,381 - 137,554	20	22	22
VII	89,966 - 142,886	8	8	8
EX (Level II)	133,600	1	1	1
		72	72	72