Saturday, May 02, 2020 1:27:03 PM
Oh, you were looking at the 10-Q. I was looking at the 10-K from Q4 2019.
The numbers aren't much different; the sheer size of FnF is shown by the fact that $2.5B doesn't make much of a difference.
He still has to go through the process of formally proposing the rule, having a comment period, and either re-proposing the rule or finalizing it after the comment period is over. Watt started this process near the end of his term but it was never finished.
But make no mistake: Calabria's minimum capital requirement (not the statutory one) is the one that will have teeth. Calabria's is the one that will determine FnF's capitalization level by HERA, and FnF having less core capital than Calabria's minimum standard is what will make them "significantly undercapitalized", which in turn gives Calabria the authority to determine the form and amount of the capital raise.
Everything is connected.
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