BayCoast Bank
BayCoast BankSupportBusiness
Summary: BayCoast Bank, a community bank, supports the Agencies' objectives of enhancing risk sensitivity and consistency in capital requirements. However, they petition for specific modifications, including reducing the Mortgage Servicing Assets (MSA) risk weight to 100%, recognizing private mortgage insurance (PMI) as a risk mitigant, and incorporating broader credit quality factors beyond LTV.
Dear Chief Counsel’s Office:
On behalf of BayCoast Bank, please find attached our comment letter regarding the Notice of Proposed Rulemaking titled “Regulatory Capital Rules: Regulatory Capital and Standardized Approach for Risk‑Weighted Assets” (Docket ID OCC‑2026‑0034; RIN 1557‑AF49), published March 27, 2026.
We appreciate the opportunity to provide our perspective and would welcome further engagement with OCC staff regarding our comments.
Please feel free to contact me with any questions.
Respectfully,
Casey N. Brouthers
SVP/Chief Risk Officer & General Counsel