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Re: navycmdr post# 770525

Wednesday, 10/11/2023 2:59:48 AM

Wednesday, October 11, 2023 2:59:48 AM

Post# of 796428
It wasn't a Proposed Rule to begin with, but a Request for Input (RFP, not a comment period for a Proposed Rule) about the upfront g-fees (LLPA) recently updated, that even there was a question whether they should exist at all. So, the FHFA is clueless and it just pretends to be a busy regulatory Agency engaging in public debates, when there was no need.

Therefore, it had nothing to do with the Capital Rule and its Basel framework. The complains about Basel are low profile, because it's an international standard for the same risk exposure.
This is what happens when you don't want the prior UST backup of FnF "at rates that take consideration the Treasury yields as of the last day of the month preceding the purchase" and you don't want to subsidize the guarantee fee (FnF was accused by the CBO of delivering below private sector g-fees to increase market share and called it "subsidy cost" charged into the Federal Budget at the time), which was part of the Charter dynamics.
The goal during Conservatorship was to increase the g-fees, so FnF compete on a level playing field and in order to bring in more competition from the fully private sector, reducing their market share (shrink footprint)
This is an excerpt explaining it, taken from the famous 2011 UST-HUD Housing Finance System revamp with the ultimate endgame: a 3-option plan Privatized Housing Finance System chosen by the UST as "recommendations on ending the conservatorships, no later of January 31, 2011", at the request of the Dodd-Frank Act, explaining it:

Finally, the Credit Risk Transfers (CRTs) are unauthorized in the Charter's Credit Enhancement clause and likely a backdoor Commitment Fee to enrich the UST, which is also barred in the Fee Limitation clause. We are requesting a refund of the CRT expenses, net, as explained yesterday. More reasons why the Charter ought to be revoked.