As promised, we have completed an in-depth analysis of the FSOC’s final standards for designating nonbank financial companies as SIFIs. None of the specifics of the rule have changed from the proposal in ways that affect the GSEs, meaning that Fannie, Freddie and the FHLBs are all clearly systemic under FSOC standards. Or, they would be if Secretary Geithner hadn’t said that he doesn’t see Fannie and Freddie as systemic anymore.

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