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:
- 1 comment from the past week
One comment matches your current view and arrived in the last week. Read this week's comments with stance, commenter type, and AI summaries on the paid plan.
- Jun 18, 2026The Coalition for Derivatives End-UsersOpposeAdvocacy📎 Attachment
The Coalition for Derivatives End-Users, representing 94 companies, associations, and municipalities, opposes the proposed capital requirements for uncleared derivatives with commercial end-users. They argue that the proposal creates redundant capital charges, places U.S. companies at a competitive disadvantage compared to the EU, and imposes undue costs on legitimate hedging activities.
Read comment → - Jun 18, 2026Structured Finance AssociationOpposeTrade association📎 Attachment
The Structured Finance Association (SFA) opposes several provisions in the proposed rules, particularly the addition of the word "solely" to the definitions of traditional and synthetic securitization, arguing it creates arbitrary capital requirements and ignores economic substance. They also request clarifications on relying on existing interpretive frameworks for investment firm exposures and advocate for several specific modifications to risk-weighting and parameter calculations.
Read comment → - Jun 18, 2026Mechanics BankOpposeBusiness📎 Attachment
Mechanics Bank opposes the proposed 90 percent risk weighting for loans secured by the cash surrender value (CSV) of life insurance policies. The bank argues that a 20 percent risk weighting would more accurately reflect the low risk of these secured loans and ensure continued access to these products for customers.
Read comment → - Jun 18, 2026American ExpressSupportBusiness📎 Attachment
American Express supports the proposed Basel III implementation as a substantial improvement over the 2023 proposal, noting it better aligns capital to risk. However, the company argues that the proposals are still miscalibrated for its specific business model and requests several targeted refinements to credit risk, operational risk, and market risk frameworks.
Read comment → - Jun 18, 2026Assured Guaranty Inc.SupportBusiness📎 Attachment
Assured Guaranty Inc., a financial guaranty insurer, supports the proposal's objective of bringing lending back into the regulated banking sector but argues that the current credit risk mitigation framework is poorly designed for community and regional banks. They advocate for revising the definition of "eligible guarantor" to include prudentially regulated insurance companies engaged in credit protection, arguing that the current categorical exclusion is arbitrary and inconsistent with international standards.
Read comment → - Jun 17, 2026Ally Financial Inc.SupportBusiness📎 Attachment
Ally Financial Inc. supports the agencies' proposal to modernize the regulatory capital framework and streamline capital requirements. The company specifically recommends creating a separate risk weight category for consumer automotive loans and leases with a risk weight lower than 90% to better align capital requirements with the actual risk of these assets.
Read comment → - Jun 16, 2026Congress of the United StatesSupportGovernment📎 Attachment
Congressmen Andy Barr and Jim Himes are requesting that the banking agencies modernize regulatory capital rules to categorically recognize regulated insurance companies as eligible guarantors for credit risk transfer. They argue that this change would improve international competitiveness, enhance safety and soundness, and expand access to credit for borrowers.
Read comment → - Jun 1, 2026Kentucky House of RepresentativesSupportGovernment📎 Attachment
Kentucky State Representative Michael "Sarge" Pollock supports the proposed capital requirements because he believes they will lower the cost of living for families. He argues that by reducing unnecessary regulations, banks can offer more competitive interest rates on loans and credit cards, making it more affordable for parents to raise children.
Read comment →