Northpointe Bank

Summary: Northpointe Bank, a nationwide mortgage lender, opposes the proposed risk-based capital requirements for warehouse facilities because they assign a high corporate-style risk weight (95%) to these facilities instead of a lower weight based on the underlying mortgage collateral. The bank argues that these punitive capital requirements increase lending costs for consumers and requests that the agencies either allow a look-through approach or reduce the risk weight to no more than 50%.