Robert Kazdin 2
Robert KazdinSupportIndividual
Summary: Robert Kazdin, a former banking and housing finance official, supports the proposed rule's improvements to mortgage credit risk but argues it is insufficient because it lacks a standardized framework for interest-rate risk (IRR). He recommends that the agencies adopt a quantitative IRR capital charge, citing the 2023 banking crisis and international precedents as evidence that duration exposure requires formal capitalization.
Please see the attached comment letter regarding the March 19, 2026 proposed capital rule. The submission focuses on the treatment of interest-rate risk (IRR) and recommends consideration of a standardized capital framework for material duration exposure. Thank you for the opportunity to comment.