Allianz Trade
BusinessSupport
Regulatory Capital: Regulatory Capital and Standardized Approach for Risk-Weighted Assets
OCC-2026-0034-0001NPRM
Comments
142
Last activity Jul 23, 2026
Deadline
Closed on Jun 19, 2026
Closed Jun 19, 2026
Net supportiSupport minus oppose · campaigns included
+58%
+58% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- 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
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Stance breakdown
+58%
Net support
Support111Oppose29Other2
Aggregates include form-letter campaigns. Excluding them, net support is +58% across organic comments.
Who commented
Breakdown by commenter type.
Government
27
Individual
36
Advocacy
30
Trade association
15
Academic
2
Business
31
Other
1
Comments over time
Weekly arrivals, stacked by stance.
Posted Mar 27, 2026Deadline Jun 19, 2026
Mar 23Apr 6May 11May 25Jun 8Jun 22Jul 20
Support111Oppose29Other2
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Individual
58%
42%
0%
Business
90%
6%
3%
Advocacy
80%
17%
3%
Government
89%
11%
0%
Trade association
93%
7%
0%
Academic
0%
100%
0%
Other
0%
100%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Bank capital requirements96
Cost of credit and lending43
Housing affordability and credit access27
Reduce gsib surcharges18
Small business credit access13
Mortgage servicing assets risk weighting10
Lowering cost of credit9
Eligible guarantor definition6
Expansion of affordable credit5
Lowering mortgage costs and competition5
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
1 organization filed this week — visible to subscribers.
| 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 | · | · |
American Bankers Association
Trade associationSupport
Mortgage servicing assets risk weighting
American Express
BusinessSupport
Bank capital requirements
Arch Capital Group Ltd.
BusinessSupport
Cost of credit and lending
BAFT, Inc.
Trade associationSupport
Small business credit access
BayCoast Bank
BusinessSupport
Cost of credit and lending
BPL Global LLC
BusinessSupport
Committee on Capital Markets Regulation
AdvocacySupport
Bank capital requirements
CREFC, Nareit, NMHC, RER, ALTA, Appraisal Institute, BOMA, ICSC, NAA, NAHB, REBNY
Trade associationSupport
Bank capital requirements
Housing affordability and credit access
Fannie Mae
AdvocacySupport
Federal Home Loan Bank of Chicago
Trade associationSupport
Bank capital requirements
Mortgage servicing assets risk weighting
Home Builders & Remodelers Association of CT, Inc.
Trade associationSupport
Bank capital requirements
Housing Trust Silicon Valley
AdvocacySupport
Bank capital requirements
Housing affordability and credit access
KeyCorp
BusinessSupport
Maryland Chamber of Commerce
Trade associationSupport
Small business credit access
MDD Connections, LLC
BusinessSupport
Small business credit access
Mortgage Bankers Association
AdvocacySupport
Bank capital requirements
Cost of credit and lending
NAHB
Trade associationSupport
Bank capital requirements
Cost of credit and lending
Housing affordability and credit access
National Association of Affordable Housing Lenders
AdvocacySupport
Housing affordability and credit access
National Association of REALTORS
Trade associationSupport
Bank capital requirements
Mortgage servicing assets risk weighting
National Council of State Housing Agencies
AdvocacyOther
Bank capital requirements
Cost of credit and lending
Housing affordability and credit access
National Housing Conference (NHC)
AdvocacySupport
Bank capital requirements
Cost of credit and lending
Housing affordability and credit access
New Jersey Black Issues Convention
AdvocacySupport
Bank capital requirements
Small business credit access
Structured Finance Association
Trade associationOppose
Bank capital requirements
The Housing Policy Council
Trade associationSupport
Bank capital requirements
TWK Advisors LLC
BusinessSupport
U.S. Mortgage Insurers (USMI)
AdvocacySupport
Bank capital requirements
UCM, Inc
BusinessSupport
Mortgage servicing assets risk weighting
Valley National Bank
BusinessSupport
Bank capital requirements
Cost of credit and lending
Small business credit access
8 organization-typed comments could not be identified.
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- Jun 18, 2026BayCoast BankSupportBusiness📎 Attachment
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.
Read comment → - Jun 18, 2026The Housing Policy CouncilSupportTrade association📎 Attachment
The Housing Policy Council, a trade association of mortgage lenders and insurers, supports the proposed rules for aligning capital requirements with the risk of mortgage exposures. They argue the rules will improve risk sensitivity, promote a level playing field, and unlock lending capacity, while also suggesting specific refinements to risk weights for mortgage servicing assets and private mortgage insurance.
Read comment → - Jun 18, 2026Arch Capital Group Ltd.SupportBusiness📎 Attachment
Arch Capital Group, Ltd. supports the agencies' intent to implement risk-based capital requirements but argues that the current proposals fail to recognize the loss-mitigating benefits of private mortgage insurance (MI). They propose specific amendments to allow banks to recognize MI coverage (subject to a counterparty haircut), unlock insurance-based credit risk transfer (CRT) by expanding the definition of eligible guarantors, and reduce risk weights for prudentially regulated eligible guarantors.
Read comment → - Jun 18, 2026U.S. Mortgage Insurers (USMI)SupportAdvocacy📎 Attachment
U.S. Mortgage Insurers (USMI), representing private mortgage insurance companies, supports the agencies' efforts to modernize bank capital rules. They argue that the final rules should explicitly recognize private mortgage insurance (MI) in the calculation of risk weights for residential mortgage exposures to better reflect its role in reducing loss severity and supporting affordable homeownership.
Read comment → - Jun 18, 2026First Mutual Holding Co.SupportBusiness📎 Attachment
First Mutual Holding Co., a federally-chartered multi-bank mutual holding company, supports the agencies' objective of strengthening the risk-based capital framework. They specifically advocate for adopting the LTV-based risk-weight framework for residential real estate, removing the mortgage servicing asset (MSA) deduction, and recognizing private mortgage insurance (PMI) as a credit risk mitigant.
Read comment → - Jun 18, 2026National Housing Conference (NHC)SupportAdvocacy📎 Attachment
The National Housing Conference (NHC) supports the proposed revisions to risk weights for residential mortgage loans but urges the agencies to revisit calibrations for high LTV loans and recognize the risk-mitigating role of private mortgage insurance. The organization also advocates for lower risk weights on Low-Income Housing Tax Credit (LIHTC) investments, mortgage servicing rights, warehouse lines of credit, and GSE multifamily mortgage exposures to better align capital requirements with observed risk and support housing affordability.
Read comment → - Jun 18, 2026National Association of Affordable Housing LendersSupportAdvocacy📎 Attachment
The Affordable Housing Tax Credit Coalition and several other organizations are urging the agencies to reduce the risk weight for LIHTC equity investments and associated loans to 20%. They argue that the current 100% risk weight is inconsistent with the historically strong performance and low foreclosure rates of LIHTC properties compared to other real estate assets.
Read comment → - Jun 18, 2026CSBSSupportGovernment📎 Attachment
The Conference of State Bank Supervisors (CSBS), representing state banking regulators, supports the proposed rules to enhance risk sensitivity and transparency in the regulatory capital framework. However, they recommend specific modifications, including expanding the Community Bank Leverage Ratio (CBLR) framework, maintaining current credit conversion factors for short-term commitments, and ensuring consistent treatment for nondepository trust companies.
Read comment → - Jun 18, 2026CREFC, Nareit, NMHC, RER, ALTA, Appraisal Institute, BOMA, ICSC, NAA, NAHB, REBNYSupportTrade association📎 Attachment
A coalition of 11 real estate trade associations supports the proposed revisions to the risk-based capital framework but requests further refinements to better calibrate capital requirements for commercial and multifamily real estate (CRE) exposures. They argue for specific adjustments to risk weights for various CRE structures, including multifamily loans, LIHTC investments, and mortgage servicing rights, to ensure the banking sector can continue to support a functioning real estate market.
Read comment → - Jun 18, 2026Mortgage Bankers AssociationSupportAdvocacy📎 Attachment
The Mortgage Bankers Association (MBA) supports the proposed revisions to the risk-based capital framework, particularly the removal of the "gold-plating" surcharge for residential real estate. However, they argue the proposals should be further improved by reducing the risk weight on mortgage servicing assets (MSAs) to 100% and providing more favorable capital treatment for warehouse lines and private mortgage insurance (PMI).
Read comment →