In this report, we build on our initial summary of FHFA’s final capital construct to assess one of the most important issues on which FHFA made at least some concessions:  CRT.  However, no matter these concessions, the final rule still makes it more capital-efficient for a GSE to hold a position on its books than to transfer some or all of its risk in synthetic structures.  Although the final approach is still more liberal than the rules governing like-kind bank CRT structures, it will surely impede GSE risk transfers and thus anger those such as Freddie Mac and many on the Street pressing for the GSEs to become capital-market players. The final rule somewhat liberalizes capital treatment for MI exposures and remains considerably more favorable than the banking construct, adding a bit more incentive for straight forward securitization or, over time, perhaps also front-end CRT.

GSE-112320.pdf