Mortgage Bankers Association
Mortgage Bankers AssociationSupportAdvocacy
Summary: The Mortgage Bankers Association (MBA) supports the proposed revisions to the risk-based capital framework, particularly the removal of the "gold-plating" surcharge for residential real estate. However, they argue the proposals should be further improved by reducing the risk weight on mortgage servicing assets (MSAs) to 100% and providing more favorable capital treatment for warehouse lines and private mortgage insurance (PMI).
Attached, please find comments submitted on behalf of the Mortgage Bankers Association. Thank you.