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Date:
08/26/2020
Name:
Michael Molesky
City:
Raleigh
State:
North Carolina
Rule Number:
Federal Register Citation:
85 FR 39274
CFR:
12 CFR Part 1240
View Document:
View Document 1.91 MB

Comment

Using a stress test based on the termination and loss patterns by the same risk segments as available on Fannie Mae's Data Dashboard, I have examined Fannie Mae's single-family risk exposure solely as a guaranty operation to determine capital adequacy of the proposed levels of capital. The tests reveal that requiring bank-like capital for holding mortgages as an asset may be appropriate, but not for risks presented as a guaranty operation.

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