Two basic points:
First, courts have affirmed that FHFA as conservator has NO fidicuiary duty to shareholders;
and,
second, courts have affirmed that FHFA as conservator is supposed to maintain companies in sound and solvent manner
Converting JPS to common INCREASES CET1 capital and hence furthers RnR, and an offering, thus furthering solvency
Consequently the courts have also found that such a decision by FHFA as conservator would NOT be reviewable by the courts