David Stephens Mortgage Consulting
David StephensSupportIndividual
Summary: David Stephens, a mortgage banking consultant, supports the proposal to eliminate the threshold-based deduction for mortgage servicing assets (MSAs) but argues that the agencies should further reduce the risk weight for MSAs from 250% to 100%. He contends that the 250% weight is punitive and lacks empirical justification, and that a lower risk weight would improve market liquidity and competition.
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