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  • Comment Detail

  • Date: 08/12/20
    First Name: Bob
    Last Name: Dearborn
    Organization: RTD Real Estate Services, Inc.
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA95

  • Comment

    Given the special purpose of the GSE's mandated by the US Congress in their charter, to promote only US residential real estate and which FDIC data shows a loss on average of 15 basis points, a 3.9% capital ratio is 26 times the amount of capital required to cover 1 year of losses. This over capitalization of 2 private corporations will result in excess dead capital that will result in lower return on equity and ultimately increase the guarantee fees as these corporations will have to compete for private equity capital. This will negatively affect all Americans residential real estate as the fees permeate throughout the US residential real estate market. If the Federal Reserve wants the GSE's to have a fortress balance sheet to further their monetary policy goals, and be over capitalized, then they should write a check for the amount of over capitalization.