CRE Finance Council
CRE Finance CouncilSupportTrade association
Summary: The Commercial Real Estate Finance Council (CREFC) generally supports the proposed revisions to the risk-based capital framework, noting that they incorporate several requested industry improvements. However, the organization requests specific refinements to ensure capital requirements for commercial real estate (CRE) exposures are accurately calibrated to risk, maintain competitive equity across different bank sizes, and preserve essential financing channels.
Please see attached for CRE Finance Council's response to the proposed Regulatory Capital: Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations.