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  • Comment Detail

  • Date: 09/15/21
    First Name: terry
    Last Name: johnssen
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB17

  • Comment

    What risks does the 2.5% cover? Does the other 0.5% cover something else? I think you should start at zero. Then add more capital for each risk. Finally sum them up. If the total is less than 2.5% (min requirement given by God), you choose 2.5%. I have had a technical role in secondary mortgage finance. My gut feeling is less than 2% capital if done in a scientific way.