CREFC, Nareit, NMHC, RER, ALTA, NAA, NAHB, BOMA, Appraisal Institute, REBNY, ICSC
CREFC, Nareit, NMHC, RER, ALTA, NAA, NAHB, BOMA, Appraisal Institute, REBNY, ICSCSupportTrade association
Summary: A coalition of 11 real estate trade associations supports the proposed revisions to the risk-based capital framework but requests specific refinements to better calibrate capital requirements for commercial and multifamily real estate (CRE) exposures. They argue for more granular risk weights, broader definitions of regulatory CRE to avoid structural penalties, and lower risk weights for specific assets like multifamily loans, LIHTC investments, and DUS exposures to ensure continued support for the CRE market.
Please see attached for response to the proposed Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations by 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