*** Timeline of the Fanniegate scandal ***
Nothing has been done by chance. This is why the FHFA Final Rule in 2016 for the FHLB membership cleansing, that was first proposed in 2010, gave 5 years to the FHLBanks to "wind down their affairs with the captive insurers".
It's 2021 when FnF became Undercapitalized (a percentage of the Adjusted Total Assets -Leverage ratio-), which makes them Adequately Capitalized because the threshold (a percentage of the RWA -Risk-Based Capital requirement-) is lower in FnF.
But the FHFA realized that, at the time, the JPS couldn't be redeemed at par value and, even when their fair value fetched their par value with the estimated resumption of dividend payment later on, it couldn't be done either, as the JPS are Core Capital and thus, if they are redeemed, FnF wouldn't meet the ERCF.
It's not until CET1 > 2.5% of Adjusted Total Assets when the JPS can be redeemed and then, continue to meet the ERCF with Tier 1 Capital > 2.5% of Adjusted Total Assets.
Wait! Because the FHFA wanted to meet another threshold, which is 25% of the Prescribed Capital Buffer after the redemption of the JPS, for the normalcy in FnF with the resumption of dividend payment, upon announcement of the Privatized Housing Finance System chosen for the release by the UST in a 2011 Report to Congress, at the request of the Dodd-Frank law: "Recommendations on ending the Conservatorships".
The last threshold possible was met by the laggard Fannie Mae with the 4th quarter Earnings report released a few weeks ago. After that, we are in unchartered (Act) territory. There are no more thresholds under the Separate Account plan.
