KeyCorp and KeyBank National Association
KeyCorpSupportBusiness
Summary: KeyCorp and KeyBank National Association support the proposed rule as an improvement over previous revisions, noting its better alignment with risk profiles. However, they specifically argue that the agencies should further lower the risk weight for low-income housing tax credit (LIHTC) investments to 50% to accurately reflect their low risk and avoid market distortions.
On behalf of KeyCorp and KeyBank National Association, please find attached comments on the proposal titled Regulatory Capital Rules: Regulatory Capital and Standardized Approach for Risk-Weighted Assets.