@dpp @jgordon I think you’d want not to let the amount of these gap notes depend on individual transaction prices and home values. It’s too gamable. The government could develop zillow-like notional values and rely upon those and just the purchase and sales dates. There’d be some legit “basis risk”, as your home’s value evolution might differ from the Fedestimate, but it’d be very hard to police overpriced purchases underpriced sales + side agreements. 2/