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  • Comment Detail

  • Date: 08/26/20
    First Name: Michael
    Last Name: Molesky
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA95

  • Comment

    Using a stress test based on the termination and loss patterns by the same risk segments as available on Fannie Mae's Data Dashboard, I have examined Fannie Mae's single-family risk exposure solely as a guaranty operation to determine capital adequacy of the proposed levels of capital. The tests reveal that requiring bank-like capital for holding mortgages as an asset may be appropriate, but not for risks presented as a guaranty operation.