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  • Comment Detail

  • Date: 08/22/18
    First Name: Capital Requirements based on Utility and General
    Last Name: Utility and General Business Models
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA95

  • Comment

    Capital Requirements based on Utility and General business Models

    For the purpose of determining true risk based Enterprise Capital Requirements in a fair and reasonable manner
    FnF business needs to be classified in to 2 categories.

    1. Gov Policy Mandated Utility Business Model:
    This business is to comply with Gov policy based mandates like affordable housing , counter cyclical roles...
    This should be considered as utility model based business. For this type of business, Gov should underwrite all FnF business transactions/investments, guarantee resonable ROI and pay service fees. So there should not be any capital requirements since this business is underwritten by Gov.

    2. General Business Model:
    For this type of business, the capital requirements must determined based type of risks involved. Since FnF are involved specialized insurance business, the insurance standards should be used and not the banking standards.