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Alias Born | 07/18/2020 |
Monday, August 31, 2020 4:04:15 PM
"Former FDIC Vice-Chair Tom Hoenig has written an excellent comment letter on the
FHFA’s proposal, with a particularly good discussion of leverage ratios, which I support and commend
to the FHFA."
Dr. Hoenig, says 4+% is too low it should be 5% or HIGHER!
Here's Sheilas personal comment letter conclusion:
"To protect lower wealth borrowers and lead to a more inclusive system of housing finance, the
distribution of capital is at least important as the quantum. Adequate capitalization is necessary for
financial stability. We know that financial instability caused by excessive leverage in the financial
system most severely impacts low wealth families and families of color. I do not discount concerns
that higher capital requirements will place pressure on guarantee fees. Yet the degree of those g-fee
increases will be impacted by a variety of factors including the exposures to which the new capital
rules apply going forward, the time period over which the capital needs to be raised, and the desired
level of returns on equity once the Enterprises exit from conservatorship. It should be noted that
giving the Enterprises more latitude to diversify revenue sources could make them more stable
institutions, while easing pressure on g-fees which lenders all too quickly pass on to borrowers. This
too would need to be carefully done to avoid “charter creep” but is worth exploring.
Having advocated for stronger capital rules throughout my career, I appreciate the challenges of the
task before you. I congratulate you on a thoughtful, well-crafted proposed capital framework. Again,
these are my personal views and do not represent the views of any other organization with which I am
or have been affiliated. Thank you for the opportunity to present them."
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