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.