Analysis of the FHFA Proposal on Enterprise Capital

Research Report

Analysis of the FHFA Proposal on Enterprise Capital


The Federal Housing Finance Agency’s (FHFA) recently issued a proposed capital standard for the government-sponsored enterprises (GSEs), Freddie Mac and Fannie Mae. In this brief, we analyze how well the rule aligns risk and capital across the various mortgage attributes and how capital requirements vary across the business cycle, to begin to understand whether the capital standards are appropriately calibrated. Our principal observations are as follows:

  1. In general, the FHFA has captured the most important risk attributes and directionally has aligned capital with the risk.
  2. For high-risk mortgages, especially products used by first-time homebuyers and for many low- and moderate-income households, the proposal overpenalizes risk—that is, allocates more capital than the data would support.
  3. The standard is procyclical, with capital standards either doubling or halving in a two-year period.


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