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Date:
08/22/2018
Name:
Capital Requirements based on Utility and General Utility and General Business Models
Rule Number:
Federal Register Citation:
83 FR 33312
CFR:
12 CFR Parts 1206, 1240, and 1750

Comment

Capital Requirements based on Utility and General business Models

For the purpose of determining true risk based Enterprise Capital Requirements in a fair and reasonable manner 
FnF business needs to be classified in to 2 categories.

1. Gov Policy Mandated Utility Business Model:
This business is to comply with Gov policy based mandates like affordable housing , counter cyclical roles...
This should be considered as utility model based business. For this type of business, Gov should underwrite all FnF business transactions/investments, guarantee resonable ROI and pay service fees. So there should not be any capital requirements since this business is underwritten by Gov.
 
2. General Business Model: 
For this type of business, the capital requirements must determined based type of risks involved. Since FnF are involved specialized insurance business,  the insurance standards should be used and not the banking standards.

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