Thursday, May 28, 2020 2:18:06 AM
The FHFA's reproposal of the Capital rule isn't a political document or it doesn't treat FnF as banks for similar exposures, as the conspirators now repeat, because the banks have different formulaic (flat 50% risk weight). The problem comes when the FHFA compares FnF with the U.S. banks and U.S. bank holding companies in the outcome of the Capital requirements and, most importantly, the TOP 10 technical flaws in the report:
1- The figures of risk weight.
2- The use of a 15% floor in the risk weight.
3- Establish a minimum common equity CET1.
4- The Leverage capital is higher than the Risk-Based Capital requirement which renders the later void, as complying with the first, complies with the latter (Then, the 424 pages in the report are a waste of time)
5- A 0% payout until the Total Capital is 25% of the Capital Surplus.
6- Only 1 year to meet the Capital requirements in the absence of Conservatorship.
7- Usage of CRT when FnF are insurers.
8- The reserve for CECL or Allowance isn't recorded as TIER2 Capital.
9- $99 billion of Capital Surplus (buffer) or 73% of $135 billion, is excessive.
10- Calabria raised the Operational Risk from 8bp in Watt's rule, to 15bp.
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