Skip to main content

  • Comment Detail

  • Date: 08/08/20
    First Name: Robert
    Last Name: Dearborn
    Organization: RTD Real Estate Services, Inc.
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA95

  • Comment

    Why use an International Commercial Banking Capital Requirement (i.e., Basel.III) when you have readily available ACTUAL HISTORICAL LOSS DATA going back decades on the ONLY asset class the GSE's are legally chartered to invest in (i.e., US residential real estate)? I think historically his figure is 15 basis points. Over capitalizing the GSE's will have negative consequences for all Americans and their BIGGEST expense!