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  • Comment Detail

  • Date: 02/09/22
    First Name: James B.
    Last Name: Lockhart III
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB16

  • Comment

    The GSEs are required to submit their capital plans by May 20th. The capital plans will allow the Enterprises to identify the amount of capital they need to raise to close the gap with the ERCF, and to consider the timing of when to raise capital, and what types of capital to raise. This assumes that FHFA and Treasury will make significant reductions or eliminate the liquidation preference either prior to May 20th- or the GSEs are to assume that the liquidation preference will not be a hinderance in their plans. I propose that verbiage be added to the rule, that clearly establishes the ground rules. Otherwise, why go through the process?