Fannie Mae

Summary: Fannie Mae argues that the proposed rule creates an "unwarranted divergence" by maintaining a 20 percent risk weight for GSE senior debt and guaranteed MBS while lowering the floor for comparable non-GSE securitizations to 15 percent. The organization requests that the Agencies align the risk weight for GSE exposures with the lower 15 percent floor to better reflect their high credit quality, liquidity, and structural simplicity.