| 来源类型 | Testimony |
| 规范类型 | 其他 |
| Comment letter to FHFA: Enterprise Capital Requirements | |
| Edward J. Pinto; Lynn M. Fisher | |
| 发表日期 | 2018-11-16 |
| 出版年 | 2018 |
| 语种 | 英语 |
| 摘要 | Executive Summary This proposal is important, despite its inapplicability to the GSEs in conservatorship, because it is intended to serve as guide to estimating capital costs in pricing new business activities and because it may serve as a guide to what is appropriate capital for similar post-conservatorship institutions. Getting this right is of particular importance because the GSEs currently back nearly one half of the institutionally financed single family housing transactions in the US, and the last regulatory effort to establish appropriate capital levels for the GSEs ended in a spectacular failure, notwithstanding spending a decade-long regulatory effort to develop capital standards. The proposed rule pays insufficient attention to the unique risks attendant to the mortgage guarantee business and the GSEs’ outsized role in this business. Specifically, its binding, risk-based rules would not require enough capital to address another housing crisis of comparable magnitude to the most recent one, and its minimum leverage ratios would not be consistent with requirements for global systemically important banks (G-SIBs) given the de facto status of the GSEs as systematically important financial institutions (SIFIs). The result would be underpricing of risks and exacerbation of house price cycles. Our recommended changes to the capital requirements, with a focus on single-family whole loans and guarantees, would result in additional risk-based capital of more than 200 basis points relative to FHFA’s proposal and a minimum leverage ratio of 4 percent. Read the full comment letter here. |
| 主题 | Housing Center ; Housing Finance |
| 标签 | Federal Housing Finance Agency (FHFA) ; GSEs (Fannie Mae and Freddie Mac) ; Housing Center: Policy |
| URL | https://www.aei.org/research-products/testimony/comment-letter-to-fhfa-enterprise-capital-requirements/ |
| 来源智库 | American Enterprise Institute (United States) |
| 资源类型 | 智库出版物 |
| 条目标识符 | http://119.78.100.153/handle/2XGU8XDN/209878 |
| 推荐引用方式 GB/T 7714 | Edward J. Pinto,Lynn M. Fisher. Comment letter to FHFA: Enterprise Capital Requirements. 2018. |
| 条目包含的文件 | ||||||
| 文件名称/大小 | 资源类型 | 版本类型 | 开放类型 | 使用许可 | ||
| FHFA-Capital-Proposa（881KB） | 智库出版物 | 限制开放 | CC BY-NC-SA | 浏览 | ||
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