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Re: DCBill post# 762696

Monday, 08/14/2023 6:29:24 PM

Monday, August 14, 2023 6:29:24 PM

Post# of 793418
The misapplication of using International Commercial Bank Capital Ratios instead of those appropriate for a monoline insurance company should not be overlooked. Another major flaw is no credit for incoming Guarantee Fee Income paid by borrowers on the book of business during times of stress.