Arch Capital Group Ltd.

Summary: Arch Capital Group, Ltd. supports the agencies' intent to implement risk-based capital requirements but argues that the current proposals fail to recognize the loss-mitigating benefits of private mortgage insurance (MI). They propose specific amendments to allow banks to recognize MI coverage (subject to a counterparty haircut), unlock insurance-based credit risk transfer (CRT) by expanding the definition of eligible guarantors, and reduce risk weights for prudentially regulated eligible guarantors.