Commercial Real Estate Financial Council, American Land Title Association, Appraisal Institute, et. al
CREFC, Nareit, NMHC, RER, ALTA, Appraisal Institute, BOMA, ICSC, NAA, NAHB, REBNYSupportTrade association
Summary: A coalition of 11 real estate trade associations supports the proposed revisions to the risk-based capital framework but requests further refinements to better calibrate capital requirements for commercial and multifamily real estate (CRE) exposures. They argue for specific adjustments to risk weights for various CRE structures, including multifamily loans, LIHTC investments, and mortgage servicing rights, to ensure the banking sector can continue to support a functioning real estate market.
Please see attached a response to the proposed Regulatory Capital and Standardized Approach for Risk-Weighted Assets from 11 trade associations: CRE Finance Council
American Land Title Association
Appraisal Institute
BOMA International
ICSC
Nareit
National Apartment Association
National Association of Home Builders of the United States
National Multifamily Housing Council
The Real Estate Board of New York
The Real Estate Roundtable