Monday, August 31, 2020 1:33:29 AM
He attacks the core of the Capital rule:
1-The risk weights for the Risk-Based Capital requirement. If it fails in the risk weights for the risk-weighted assets, better do another job.
2-The Leverage Capital or Minimum Capital: the FHFA proposes a whopping 4% of total Assets whereas the CFO proposes 4% of on-balance sheet assets and 1.5% of the guarantee portfolio (MBSs). The current law in force establishes 2.5% of on-balance sheet assets and 0.45% of the g-portfolio.
The FHFA has lost all sense of reality because it has another agenda: increased capital needs for CRT expenses and follow-on stock offerings that enrich the investment bankers.
What is left in the Capital rule is the CRT scam, ill-conceived for insurers and a scam, and the Affordable Housing role, a myth because now FnF are charging the same guarantee-fee that the fully private sector would charge, 59bp for taking on the risk of only 80% LTV of a 100% LTV mortgage, because the borrower pays for the remainder. Or lower LTV at origination if the borrower puts money down to save the insurance payment PMI. Congress to step in.
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