Skip to main content

  • Comment Detail

  • Date: 07/03/18
    First Name: Carlos
    Last Name: Vignote
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA95

  • Comment

    The Risk-Based Capital is flawed. The 2 Capital requirements are applied simultaneously, but are not additive.
    However, the FHFA has added a minimum capital (75bp; $40b) called Going-Concern Buffer into the Risk-Based Capital, when there's a Minimum Capital requirement already, called Minimum Leverage Capital.