Friday, October 07, 2016 9:25:01 AM
https://www.govtrack.us/congress/bills/110/hr3221/text
Please refer to Sec. 1111 and the concluding statements therein that expressly empower the Director to establish additional capital or reserve requirements" necessary to operate the entities in a safe and prudent way.
That is what the law says. So any pundit or plaintiff can critique the reserves, all they want, but such actions are within the law and there is nothing in HERA that requires any specific metric to be used by the Director. Just his judgement, as I read HERA.
JMHO.
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