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Date:
08/17/2020
Name:
Jonathan Glowacki
City:
Brookfield
State:
Wisconsin
Organization:
Milliman
Rule Number:
Federal Register Citation:
85 FR 39274
CFR:
12 CFR Part 1240
View Document:
View Document 1.91 MB

Comment

The proposed capital rule results in uneconomical capital charges for CRT and does not fully recognize the benefits of CRT as an effective source of capital. We recommend adjustments to the framework to recognize the benefits and loss absorbing capacity of CRT.

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