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Date:
06/24/2020
Name:
Paul Cheung
Rule Number:
Federal Register Citation:
85 FR 39274
CFR:
12 CFR Part 1240
View Document:
View Document 1.91 MB

Comment

Total bailout in 2008 was $180B. At that time, there were messy sub-prime loans and alt-A loans. 

Now, the GSEs have implemented improvement measures such as the Credit Risk Transfer and robust credit scoring system. There is no more sub-prime or alt-A loans. The capital requirement should be far less than $180B. Higher than required capital will imply unnecessary higher mortgage interest rate to the mortgagee.

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