Wise Man
2 hours ago
The regulatory capital has the purpose to cover the future "unexpected" losses.
The "expected" losses are covered by the Loan Loss Reserve that doesn't appear in the Net Worth.
And we have Calabria who recently said in an article that the Net Worth absorbs the credit losses in mortgages.
A former FHFA Director refusing to talk in technical terms and wrong, and prefers to go full "unsophisticated" mode.
The Loan Loss Reserve is better known as the Allowance for Credit Losses, currently $15.4B in FnF together, under the CECL accounting standard (Current Expected Credit Losses), a provision set aside even the very moment of purchase of the mortgage.
No CECL for the banks' Commercial Real Estate loans?
But "expected" losses means that, besides loans individually impaired, it's also being used as "General Reserve for Loan Losses", based on the assessments of the management about the foreseeable future, which may be wrong and this reserve might end up being released (Benefit for Loan Loss in the Income Statement).
This Allowance for Credit Losses appears on the Balance Sheet as Asset write-down, reducing the mortgage assets because it assumes that the loss already occurred, when it's false. This is why the portion that is a General Reserve, is recorded as low quality TIER 2 Capital to calculate the Total Capital that has to meet the 8% of the Risk-Weighted Assets (FnF, U.S. banks and Basel).
In FnF, the full Allowance for Loan Losses is recorded as Tier 2 Capital. Thus, it's all a General Reserve.
The credit losses or "charge-offs" during the period, are debited from this Loan Loss Reserve already built with the prior provisions set aside. The credit losses don't appear on the Income Statements. The provisions had already prompted the losses on the Income Statements in the past.
More evidence that puts into question the concept of "Capital Buffer" through regulation, because this Loan Loss Reserve is the first "buffer", not recorded as capital. In what looks like Capital Buffers to protect the "Fairholmes of the world" that enjoy a high dividend rate on Preferred Stocks and don't want Prompt Corrective Actions as we've seen with FnF with the dividend suspended, and instead, they use their JPS for the assault on the ownership interest after inflicting the insolvency in their prey on purpose, for instance, with outstanding provisions set aside. Sounds familiar?
There is a limit in the amount of Allowance for Credit Losses that can be recorded as TIER 2 Capital, of 0.6% of the RWA, written in the FHFA Capital Rule, the same as Basel, no limit in the FHEFSSA.
Calabria's HERA struck the section in the FHEFSSA with the Risk-Based Capital requirement, so we don't see published the swelled Allowance for Credit Losses in early Conservatorship with the Obama's loan modifications spree that artificially swelled the provisions set aside, recorded as Tier 2 Capital in the Total Capital, to meet this threshold, as seen today:
Freddie Mac: remember that the Core Capital is assessed badly, because the Core Capital is calculated with the sum of its components (FHEFSSA image below), not beginning with Equity, less SPS, less AOCI (it can be deemed a felony):
FHEFSSA:
pending a new Capital Rule that took 13 years to make, due to the absence of the section 18-month IMPLEMENTATION in HERA, as usual in the FHEFSSA.
This is why we've had N/A in the FHFA Reports to Congress (Obscurantism) until then:
This concept of Allowance for Credit Losses accounted for in the Total Capital provided that it's a General Reserve, is written in the FHEFSSA definition of Total Capital, Basel and the FHFA Capital Rule.
FHEFSSA:
Wise Man
1 day ago
SPS aren't regulatory capital. $402B core capital shortfall over Minimum (Leverage) Capital requirement, makes the debate about capital requirements in FnF, pointless. Brought to you by the controversial member of Fairholme's legal team, Timothy Howard, all day with "bank-like", when the Basel framework for capital requirements is assessed for the same credit exposure.
As required by the Treasury Department in 2011 for the release from conservatorship: increase the guarantee fees so that FnF are subject to the same capital standards as the fully private banks (Basel framework). That is, a Charter revoked scenario (no UST backup of FnF anymore, "GSEs")
Minimum Risk-Based Capital requirement: The CET1 and Total Capital requirements as percentage of the Risk-Weighted Assets (RWA), coincides with the U.S. banks and Basel (4.5% and 8%, respectively. ERCF tables)
But with regard to the minimum Leverage ratio in FnF (previously known as Minimum Capital level), the TIER 1 Capital > 2.5% of Adjusted Total Assets, stands below the U.S. banks with TIER 1 Capital > 3% of Total Assets. This is the binding capital requirement in FnF (highest).
Here the FHFA might have considered their monoline insurance business model.
The FHFA's "back-end" Capital Rule (unveiled after the typical Transition Period to build capital when there are changes, due to the lack of "18-month IMPLEMENTATION" section in the amendment in HERA of the FHEFSSA, like before) that came into effect on February 16th, 2021, adopted the Basel framework for capital requirements.
It means that it's a framework and the FHFA or the Federal Reserve, through regulation, are allowed to change the inputs. For instance:
▪️The Risk-Weights in the mark-to-market LTV/Credit Score matrix to calculated the RWA, an amount later multiplied by the percentage of capital requirement;
▪️A 20% Risk-Weight floor in FnF;
▪️Capital Buffers (above the minimums), which should be a decision by the management, because the minimum regulatory capital already absorbs losses directly or through Prompt Corrective Actions.
▪️The GSIBs have a surcharge.
▪️Etc.
But the Federal Agencies can't change the framework, that is, the capital metrics, their definition and, thus, the fact that the cumulative dividend SPS are NOT considered regulatory capital (not loss-absorbing capacity with the dividend suspended); The concept of "Capital Reserve" doesn't exist in the Basel framework; Likewise, the figure of "Net Worth" isn't considered to evaluate the soundness and solvency, but the capital metrics. Etc.
This rogue Ihub poster sounds familiar to me.
Any impact on Fannie / Freddie capital reserves requirements?