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  • Comment Detail

  • Date: 08/12/20
    First Name: Geoffrey
    Last Name: Stern
    Organization: Muirfield Capital Global Advisors LLC
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA95

  • Comment

    We believe the Proposed Capital Rules are unnecessarily high and require adjustments in order to minimize future guarantee fees. We propose that all or substantially all of the Proposed Buffer Capital requirements are provided by a Treasury backstop credit commitment as contemplated by the Treasury Plan. These changes would result in broad benefit to American homeowners and renters. Please see the attached letter for more details.