As promised, we here go into depth on the mortgage-market implications of the final “tailoring” rules finalized by the FRB for large holding companies and foreign banking organizations (FBOs) and by all three banking agencies (for their banks and FBO branches/agencies). The final rules track the proposals we analyzed in 2018, making it clear that large banks have new and significant incentives to increase their own mortgage portfolios and securitization operations should they choose to do so.
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