Thursday, February 29, 2024 5:44:27 AM
The FHFA was appointed conservator by the FHFA Director in 2008.
There is no ON/OFF button to choose when FnF will start the rehabilitation.
It turned out to be a typical Transition Period to build capital and meet the new thresholds, Basel framework for capital standards, chosen in 2011 for the release at the request of the Dodd-Frank law.
The prior MANDATORY release Undercap was Core Capital or Tier 1 Capital greater than 0.45% of the MBS Trusts. Now, it's 2.5%.
Regulatory Risk.
HERA removed it, this is why now we are in overtime: CET1 >2.5 % of Adjusted Total Assets (Leverage ratio)
Suitable to redeem the JPS, that is, "wind down the affairs of (FnF) with the unwanted members" (wording in a 2016 Final Rule for the expulsion of the hedge funds that used captive insurers to gain access to the FHLBanks' low cost funding).
Conservator Risk: "Best interests of the FHFA" (Incidental Power)
FHFA now wants to make up for the losses of dividend suspension for this overtime with the Lamberth rebate, even beyond the threshold 25% of the Prescribed Capital Buffer for the resumption of dividend payments (Capital Rule, Table 8: Payout ratio). So, a little bit more than Undercapitalized (The Adequately Capitalized threshold uses the Risk-Based Capital requirement. This is why it's lower. "Inverted" threshold. Howard & Co complain about this requirement, when the binding one is the other)
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