You continue to skip the FHEFSSA's Critical Capital level. You only talk about HERA, despite that HERA only inserted amendments in the FHEFSSA (and the Charter Act). Thus, without amendments, the Critical Capital level remains as is. And therefore:
An enterprise shall be classified as critically undercapitalized if— (ii)does not maintain an amount of core capital that is equal to or exceeds the critical capital level for the enterprise;
12 U.S. Code §4614(a)(4)
The FHFA is breaking the law when it doesn't post the Critical Capital level in the ERCF, as conservator of FnF. The critical capital level triggers a Conservatorship. You've been called out about this issue before. Get a grip.