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  • Comment Detail

  • Date: 07/23/20
    First Name: Justin
    Last Name: Time
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA95
  • Comment

    FHFA should reduce the capital requirement to $120B.

    The GSEs passed the 2008 housing crisis with $180B (though I don't agree they really needed the bailout). At that time, there were sub-prime loans, Alt-A loans and did not have CRT.

    The GSEs have now a more stringent credit scoring system, no more sub-prime & Alt-A loans, and a Credit Risk Transfer measure in place to adsorb the first layer loss, the capital requirement should be far less than $180B.

    Too high a capital requirement will imply unnecessary higher mortgage cost to the general public.