From: Weiser, John 
Sent: Friday, October 31, 2008 12:12 PM
To: Hunt, Nancy W.; Sheller, Ryan D.
Subject: Risk Based Capital comment

Risk capital should include FHLB and for all the GSE’s it would be wise to make it zero. Why? The market levels for GSE debt are such that they can no longer fulfill their mandate to support the mortgage market. A 10% capital requirement tells the market that they are riskier then the new Government guaranteed bank debt that is coming. Risk capital at zero would help to bring debt and mortgage spreads narrower so they could function as intended. John Weiser