We have analyzed the final FHFA rule to implement HERA provisions authorizing temporary capital increases for any or all of the GSEs. Of course, since HERA, Fannie and Freddie went into conservatorship, making moot the prospect of any capital hike for them. However, capital hikes for one or more FHLBs are very much a possibility, as evidenced by the heavy fire FHFA took when it released its proposal in this area.
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