Regulatory Capital: Regulatory Capital and Standardized Approach for Risk-Weighted Assets
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- Title
- Regulatory Capital: Regulatory Capital and Standardized Approach for Risk-Weighted Assets
The Providing Accountability Through Transparency Act of 2023 (5 U.S.C. 553(b)(4)) requires that a notice of proposed rulemaking include the internet address of a summary of not more than 100 words in length of the proposed rule, in plain language, that shall be posted on the internet website under section 206(d) of the E-Government Act of 2002 (44 U.S.C. 3501 note). In summary, the bank regulatory agencies request comment on a proposal to revise the U.S. standardized approach to better align certain capital requirements with the risk of firms’ exposures, and ensure that all large banking organizations are required to account for accumulated other comprehensive income (AOCI) in their regulatory capital to better reflect their loss-absorbing capacity. The proposal and such a summary can be found at https://www.regulations.gov by searching for Docket ID OCC–2026–0034 and https://occ.gov/topics/laws-and-regulations/occ-regulations/proposed-issuances/index-proposed-issuances.html, https://www.federalreserve.gov/supervisionreg/reglisting.htm, and https://www.fdic.gov/federal-register-publications.
- Posted
- Mar 27, 2026
- Comment period
- Mar 27, 2026 – Jun 19, 2026
- FR Doc
- 2026-05960
- CFR
- 12 CFR Part 3
Overview
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Stance breakdown
Who commented
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Comments over time
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Support × commenter type
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Issues raised
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Position map
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Issues shown
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| Organization | Bank capital requirements | Cost of credit and lending | Housing affordability and credit access | Small business credit access | Mortgage servicing assets risk weighting |
|---|---|---|---|---|---|
Allianz Trade BusinessSupport Allianz Trade supports the proposed changes to the Standardized Approach for Risk-Weighted Assets, specifically advocati | · | · | · | · | · |
American Bankers Association Trade associationSupport The Bank Policy Institute, the American Bankers Association, the U.S. | · | · | · | · | |
American Express BusinessSupport American Express supports the proposed Basel III implementation as a substantial improvement over the 2023 proposal, not | · | · | · | · | |
Arch Capital Group Ltd. BusinessSupport Arch Capital Group, Ltd. | · | · | · | · | |
BAFT, Inc. Trade associationSupport The Bankers Association for Finance and Trade (BAFT) supports the general direction of the proposed regulatory capital r | · | · | · | · | |
BayCoast Bank BusinessSupport BayCoast Bank, a community bank, supports the Agencies' objectives of enhancing risk sensitivity and consistency in capi | · | · | · | · | |
BPL Global LLC BusinessSupport BPL Global, LLC, an insurance broker, supports the proposed regulatory capital rules provided they include adjustments f | · | · | · | · | · |
Committee on Capital Markets Regulation AdvocacySupport The Committee on Capital Markets Regulation, an independent 501(c)(3) research organization, expresses broad support for | · | · | · | · | |
CREFC, Nareit, NMHC, RER, ALTA, Appraisal Institute, BOMA, ICSC, NAA, NAHB, REBNY Trade associationSupport A coalition of 11 real estate trade associations supports the proposed revisions to the risk-based capital framework but | · | · | · | ||
Fannie Mae AdvocacySupport Fannie Mae argues that the proposed rule creates an "unwarranted divergence" by maintaining a 20 percent risk weight for | · | · | · | · | · |
Federal Home Loan Bank of Chicago Trade associationSupport The Federal Home Loan Banks (FHLBanks) support the proposed rule to align capital requirements with actual risk exposure | · | · | · | ||
Home Builders & Remodelers Association of CT, Inc. Trade associationSupport The Home Builders and Remodelers Association of Connecticut supports the proposed changes to the regulatory capital fram | · | · | · | · | |
Housing Trust Silicon Valley AdvocacySupport Housing Trust Silicon Valley, a nonprofit Community Development Financial Institution (CDFI), urges regulators to reduce | · | · | · | ||
KeyCorp BusinessSupport KeyCorp and KeyBank National Association support the proposed rule as an improvement over previous revisions, noting its | · | · | · | · | · |
Maryland Chamber of Commerce Trade associationSupport The Maryland Chamber of Commerce supports the proposed reforms to the federal regulatory capital framework, noting that | · | · | · | · | |
MDD Connections, LLC BusinessSupport Marilyn D. | · | · | · | · | |
Mortgage Bankers Association AdvocacySupport The Mortgage Bankers Association (MBA) supports the proposed revisions to the risk-based capital framework, particularly | · | · | · | ||
NAHB Trade associationSupport The National Association of Home Builders (NAHB) supports the proposed regulatory capital rules because they improve ris | · | · | |||
National Association of Affordable Housing Lenders AdvocacySupport The Affordable Housing Tax Credit Coalition and several other organizations are urging the agencies to reduce the risk w | · | · | · | · | |
National Association of REALTORS Trade associationSupport The National Association of REALTORS® (NAR) supports the proposed changes to the Basel III framework, noting that they i | · | · | · | ||
National Council of State Housing Agencies AdvocacyOther The National Council of State Housing Agencies (NCSHA) comments on the proposed regulatory capital rules to advocate for | · | · | |||
National Housing Conference (NHC) AdvocacySupport The National Housing Conference (NHC) supports the proposed revisions to risk weights for residential mortgage loans but | · | · | |||
New Jersey Black Issues Convention AdvocacySupport The New Jersey Black Issues Convention (NJBIC) supports the proposed reforms to federal bank capital requirements, argui | · | · | · | ||
Structured Finance Association Trade associationOppose The Structured Finance Association (SFA) opposes several provisions in the proposed rules, particularly the addition of | · | · | · | · | |
The Housing Policy Council Trade associationSupport The Housing Policy Council, a trade association of mortgage lenders and insurers, supports the proposed rules for aligni | · | · | · | · | |
TWK Advisors LLC BusinessSupport TWK Advisors LLC, a financial services consulting firm, supports the agencies' objectives but argues that the proposal s | · | · | · | · | · |
U.S. Mortgage Insurers (USMI) AdvocacySupport U.S. | · | · | · | · | |
UCM, Inc BusinessSupport Austin Tilghman, CEO of UCM, Inc., supports the proposal to revise regulatory capital for mortgage servicing assets (MSA | · | · | · | · | |
Valley National Bank BusinessSupport Valley National Bancorp and Valley National Bank support the agencies' objectives of improving risk sensitivity and redu | · | · |
8 organization-typed comments could not be identified.
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
- Jun 18, 2026BAFT, Inc.SupportTrade association📎 Attachment
The Bankers Association for Finance and Trade (BAFT) supports the general direction of the proposed regulatory capital rules, particularly the intent to improve risk sensitivity and simplify the framework. However, they argue that the proposals could negatively impact trade finance and request specific amendments to ensure that low-risk trade products are not unfairly penalized or made more expensive for U.S. companies.
Read comment → - Jun 18, 2026Independent Community Bankers of AmericaSupportTrade association📎 Attachment
The Independent Community Bankers of America (ICBA) supports the proposed mortgage-related revisions to the Standardized Approach but argues that further refinements are needed to ensure parity with large banks. They advocate for specific risk-weight reductions for community bank assets, the inclusion of PMI in LTV calculations, and a clear justification for any capital relief provided to large institutions.
Read comment → - Jun 17, 2026Maryland Chamber of CommerceSupportTrade association📎 Attachment
The Maryland Chamber of Commerce supports the proposed reforms to the federal regulatory capital framework, noting that they simplify requirements and better align capital measures with underlying risk. The organization argues that these changes will reduce regulatory burdens and expand access to credit for small businesses and entrepreneurs.
Read comment → - Jun 14, 2026New Jersey Black Issues ConventionSupportAdvocacy📎 Attachment
The New Jersey Black Issues Convention (NJBIC) supports the proposed reforms to federal bank capital requirements, arguing that they will expand lending capacity and improve access to affordable credit. The organization emphasizes that these changes will benefit historically underserved communities by supporting homeownership, small business expansion, and economic mobility for African American residents.
Read comment → - Jun 12, 2026Valley National BankSupportBusiness📎 Attachment
Valley National Bancorp and Valley National Bank support the agencies' objectives of improving risk sensitivity and reducing complexity in the revised regulatory capital framework. However, they argue that the proposal disproportionately benefits large institutions and request specific refinements to the Standardized Approach to better account for the risk profiles of commercial real estate and commercial and industrial loans.
Read comment → - Jun 10, 2026MDD Connections, LLCSupportBusiness📎 Attachment
Marilyn D. Davis, President & CEO of MDD Connections, LLC, supports the proposal to revise the U.S. standardized approach to capital requirements. She argues that the proposal will expand access to affordable credit for individuals, small businesses, and community-based financial institutions, thereby promoting economic growth and financial inclusion.
Read comment → - May 27, 2026Consumer Alliance for a Strong EconomySupportAdvocacy
The Consumer Alliance for a Strong Economy (CASE) supports the proposal because it aims to lower capital requirements and improve the availability of affordable credit for small businesses, farmers, and entrepreneurs. They argue that the change will enhance American global competitiveness and provide essential financial opportunities for minority-owned businesses and startups.
Read comment → - Jun 18, 2026Jared CarpenterSupportGovernment📎 Attachment
Senator Jared Carpenter of Kentucky supports the proposal, arguing that it will lower borrowing costs and expand credit access for rural businesses and families by streamlining regulatory frameworks. He also suggests that the agencies should go further by reducing GSIB surcharges to unlock even more lending capacity.
Read comment → - Jun 18, 2026Jayson WilliamsSupportBusiness📎 Attachment
Jayson Williams, owner of a minority-owned community development firm, supports the proposed capital requirements rule. He argues that the proposal will lower borrowing costs and expand access to affordable credit for small businesses and homebuyers by reducing regulatory burdens and increasing competition in the mortgage market.
Read comment → - Jun 10, 2026Jamel HolleySupportGovernment📎 Attachment
Jamel Holley, a former New Jersey State Assemblyman and Mayor, supports the proposed capital requirements framework. He argues that the proposal will reduce regulatory burdens, lower borrowing costs for African American families and small businesses, and enhance America's global competitiveness.
Read comment →
