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Date:
07/23/2020
Name:
Venkat M
City:
Knoxville
Rule Number:
Federal Register Citation:
85 FR 39274
CFR:
12 CFR Part 1240
View Document:
View Document 1.91 MB

Comment

FHFA should reduce the capital requirement to $120B. The GSEs passed the 2008 housing crisis with $180B (though I don't agree they really needed the bailout). At that time, there were sub-prime loans, Alt-A loans and did not have CRT. The GSEs have now a more stringent credit scoring system, no more sub-prime & Alt-A loans, and a Credit Risk Transfer measure in place to adsorb the first layer loss, the capital requirement should be far less than $180B. Too high a capital requirement will imply unnecessary higher mortgage cost to the general public.

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