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  • Comment Detail

  • Date: 08/31/20
    First Name: Thomas
    Last Name: Helsel
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA95

  • Comment

    To whom it may concern,
    There have been many comments submitted so there is no need to reiterate some of the points raised by others.

    My comments are short and simple:
    2019 DFAST results show that credit loses over a 3yr period for Fannie and Freddie would be $12.8B collectively (22 and 26bps as % of Assets for Fannie and Freddie respectively). These results passed with the federal reserve. Much of the work in the proposed capital rule seems to be a plug back to 2008 losses driven by writing down of assets that produced catastrophic losses. These assets were then written up for massive income gains and thus huge dividends were paid to treasury.

    Is there something wrong with the way the Fed conducts DFAST? Should we be worried about the banking industry? Are you confident in the rule to that extent? How much capital should banks hold?

    Tom