RickNagra
10 시간 전
The total capital requirement of $283 billion is even higher than in the proposal.
Despite most comments that were submitted on the proposed rule finding the required capital too high, the final rule actually increases risk-based required capital by another 8 percent, or $20 billion (all figures herein as of June 30, 2020). The comments from industry sources lacked some credibility, of course, in that all beneficiaries of the mortgage system, in their own self-interest, prefer low capital requirements in order to keep mortgage credit as inexpensive as possible. However, more technical commenters (for instance, Andrew Davidson, who submitted a 17-page comment letter) also found the required capital too high. I fully concur — it is absolutely well above what is needed to support a policy of having the same capital required by other systemically important financial institutions for the same risk (which I dub “SIFI-consistency”). It is true that determining what level of capital is SIFI-consistent is difficult, given the dramatically different business models of the GSEs compared to banks. (For example, the risk to a SIFI bank from holding a mortgage loan is far higher than if a GSE held the same loan given that, unlike the bank, the GSE issues both a pass-through mortgage-backed security on it, almost wholly eliminating liquidity and interest rate risk, and a CRT, which eliminates most of its credit risk. Therefore, much less capital is required of a GSE than a SIFI bank when holding the same mortgage loan, while still retaining SIFI-consistency.) But that’s no excuse for the capital rule being so far off, and the final rule increasing it further is hard to fathom. In aggregate, the right number for required SIFI-consistent capital is, I estimate, in the $175 billion range (or about $100 billion less) on today’s combined $6.3 trillion GSE balance sheet.
https://www.jchs.harvard.edu/blog/fhfas-final-gse-capital-rule-little-credibility-and-short-shelf-life
RickNagra
10 시간 전
Even Don Layton says $283 billion is ridiculous.
The total amount of capital required, based upon the higher of a complex risk-based calculation and a simple leverage requirement (the latter being a set percentage of assets, regardless of the riskiness of those assets), was far too high at $283 billion, in particular being inconsistent with the results of the annual stress tests. This was due to the inclusion of several large, judgmentally-determined buffers (i.e. they were calculated not as a result of quantitative analysis but by the somewhat arbitrary judgment of FHFA officials). As I previously stated, based upon GSE 2019 balance sheets, I estimate the right number was in the $150-175 billion range.
https://www.jchs.harvard.edu/blog/newly-proposed-changes-gse-capital-rule-will-eliminate-harmful-distortions
NeoSunTzu
13 시간 전
Equity price increases in the secondary market (capital/stock markets) does not count for Tier 1 capital ... those equity price increases go directly into our pockets. Although, increased equity prices DOES elevate market confidence in the companies - allowing them to tap captial markets easier in the future. More importantly, the way the government originally stole the companies' capital creating their SPS, the repayment arrangements, counting repayments as only dividends, how they have conducted the fraudulent c'ship - side-stepping the c'ship's mandate - and the massive increase in capital requirements were all designed to put us in this very predicament where we'd never be able to meet these capital obligations.
That's why it is essential to call out ALL of the thievery to force them to lower the capital rule percentage to meet a level commensurate with the companies' business and market risks, force them to end the NWS without increases in liquidation preference, and to return the stolen captial above the original commitment. All of the above executed rightly and appropriately negates ANY need for a capital raise. The government should be transparent, stating they will execute the above, and over the next year to two release the companies ON THEIR OWN without the need to grease the palms of Wall Street. Leave the capital markets to put their money to more urgent and growing areas like AI, machine learning, biotech, and crypto related applications. Plenty of profit there for everyone.
EDIT: I only get one post per day and this one is running out of time to edit. Anyway, more tomorrow, but the FED and others reg agencies have already spoken of changes in the definitions and classifications of mortgages and mortgage instruments as part of tier one capital which should also give the twins a boost.
jog49
14 시간 전
"The Companies are not banks and should not be required to hold bank like capital, they do not run the same risk as banks."
The risk, for the most part is with the bans and the loans they make. F&F require the banks to bundle quality mortgages that they then buy with a tiny percentage that may go bad. The risk is significantly different. With the 2.5% figure, we are, essentially, there!
The $280B is some of Calabria's bullshit, I guess.