Affordable Housing Tax Credit Coalition
Trade associationOppose
Housing bond risk weights
Regulatory Capital: Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations
OCC-2026-0265-0001NPRM
Comments
112
Last activity Jul 23, 2026
Deadline
Closed on Jun 19, 2026
Closed Jun 19, 2026
Net supportiSupport minus oppose · campaigns included
+23%
+23% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Regulatory Capital: Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations
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 risk-based capital requirements that apply to the largest, most internationally active firms to substantially simplify the framework, better align minimum requirements with risk, improve the consistency of requirements across U.S. firms, consider overlaps with the stress capital buffer requirement, and align requirements with international standards while ensuring the framework accounts for specific features of U.S. markets. The proposal and such a summary can be found at https://www.regulations.gov by searching for Docket ID OCC–2026–0265 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
- 2026-05959
- CFR
- 12 CFR Parts 3, 6, and 32
- Topics
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Analyzed 111 of 112 comments
99%· analysis in progress
Stance breakdown
+23%
Net support
Support67Oppose41Other3Not yet analyzed1
Aggregates include form-letter campaigns. Excluding them, net support is +23% across organic comments.
Who commented
Breakdown by commenter type.
Government
5
Individual
25
Trade association
12
Advocacy
34
Academic
2
Business
32
Other
1
Not yet analyzed
1
Comments over time
Weekly arrivals, stacked by stance.
Posted Mar 27, 2026Deadline Jun 19, 2026
Mar 23Apr 6May 11Jun 8Jun 22Jul 6Jul 20
Support67Oppose41Other3
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Advocacy
76%
24%
0%
Business
78%
16%
6%
Individual
20%
76%
4%
Trade association
67%
33%
0%
Government
60%
40%
0%
Academic
0%
100%
0%
Other
0%
100%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Capital requirements for large banks71
Bank system safety concerns24
Mortgage servicing risk weights16
Banking stability and depositor protection11
Bank reserve requirements4
Expanded risk-based approach transition3
Housing bond risk weights3
Trade finance risk weights3
Boli/coli market risk exclusion2
Cross-border risk dynamics2
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 | Mortgage servicing risk weights | Capital requirements for large banks | Housing bond risk weights | Boli/coli market risk exclusion | Bank system safety concerns |
|---|---|---|---|---|---|
Affordable Housing Tax Credit Coalition Trade associationOppose The Affordable Housing Tax Credit Coalition (AHTCC) opposes the proposed 100 percent risk weight for Housing Credit inve | · | · | · | · | |
Allianz Trade BusinessSupport Allianz Trade supports the proposed regulatory capital rules but urges the agencies to adopt specific recommendations fr | · | · | · | · | · |
American Council of Life Insurers (ACLI) Trade associationSupport The American Council of Life Insurers (ACLI) supports the proposed revisions to the Basel III Endgame capital framework, | · | · | · | · | |
Asian Infrastructure Investment Bank AdvocacySupport The Asian Infrastructure Investment Bank (AIIB) supports the agencies' efforts to simplify risk-based capital regulation | · | · | · | · | · |
CREFC, Nareit, NMHC, RER, ALTA, NAA, NAHB, BOMA, Appraisal Institute, REBNY, ICSC Trade associationSupport A coalition of 11 real estate trade associations supports the proposed revisions to the risk-based capital framework but | · | · | · | · | |
Independent Community Bankers of America AdvocacySupport The Independent Community Bankers of America (ICBA) supports the proposed mortgage-related revisions but argues that fur | · | · | · | · | |
MB Schoen BusinessSupport MB Schoen, an advisory and administrative services firm specializing in Bank-Owned Life Insurance (BOLI) and Corporate-O | · | · | · | · | |
Mortgage Guaranty Insurance Corporation (MGIC) AdvocacySupport Mortgage Guaranty Insurance Corporation (MGIC), a monoline mortgage insurer, supports the proposed action but argues for | · | · | · | · | |
NAHB Trade associationSupport The National Association of Home Builders (NAHB) supports the proposed revisions to the regulatory capital framework, no | · | · | · | ||
National Association of Affordable Housing Lenders AdvocacySupport A coalition of affordable housing organizations and financial institutions is urging the regulators to lower the risk we | · | · | · | · | |
National Council of State Housing Agencies AdvocacySupport The National Council of State Housing Agencies (NCSHA) supports the agencies' efforts to modify Basel capital standards | · | · | |||
National Housing Conference (NHC) AdvocacySupport The National Housing Conference (NHC), a nonpartisan 501(c)(3) coalition, supports the proposed revisions to risk weight | · | · | · | ||
PNC BusinessSupport PNC Financial Services Group, Inc. | · | · | · | · | · |
Public Citizen AdvocacyOppose Public Citizen opposes the proposed rules, arguing that they reduce solvency standards by approximately 6 percent and in | · | · | · | · | · |
Royal Bank of Canada BusinessSupport Royal Bank of Canada (RBC) supports the proposed rule and specifically recommends that the agencies assign a 10% risk we | · | · | · | · | · |
The Bitcoin Bond Company BusinessOther The Bitcoin Bond Company, represented by its CEO, submits a comment requesting specific clarifications on how the propos | · | · | · | · | · |
U.S. Bancorp BusinessSupport U.S. | · | · | · | · | |
U.S. Mortgage Insurers (USMI) AdvocacySupport U.S. | · | · | · | · | |
West Gate Bank BusinessOppose West Gate Bank, a small community bank, opposes the proposed retention of a 250% risk weight (RW) for mortgage servicing | · | · | · | · |
Allianz Trade
BusinessSupport
American Council of Life Insurers (ACLI)
Trade associationSupport
Boli/coli market risk exclusion
Asian Infrastructure Investment Bank
AdvocacySupport
CREFC, Nareit, NMHC, RER, ALTA, NAA, NAHB, BOMA, Appraisal Institute, REBNY, ICSC
Trade associationSupport
Mortgage servicing risk weights
Independent Community Bankers of America
AdvocacySupport
Capital requirements for large banks
MB Schoen
BusinessSupport
Boli/coli market risk exclusion
Mortgage Guaranty Insurance Corporation (MGIC)
AdvocacySupport
Capital requirements for large banks
NAHB
Trade associationSupport
Mortgage servicing risk weights
Capital requirements for large banks
National Association of Affordable Housing Lenders
AdvocacySupport
Housing bond risk weights
National Council of State Housing Agencies
AdvocacySupport
Mortgage servicing risk weights
Capital requirements for large banks
Housing bond risk weights
National Housing Conference (NHC)
AdvocacySupport
Mortgage servicing risk weights
Capital requirements for large banks
PNC
BusinessSupport
Public Citizen
AdvocacyOppose
Royal Bank of Canada
BusinessSupport
The Bitcoin Bond Company
BusinessOther
U.S. Bancorp
BusinessSupport
Mortgage servicing risk weights
U.S. Mortgage Insurers (USMI)
AdvocacySupport
Bank system safety concerns
West Gate Bank
BusinessOppose
Mortgage servicing risk weights
4 organization-typed comments could not be identified.
Comments
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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.
- Jul 7, 2026Allianz TradeSupportBusiness📎 Attachment
Allianz Trade supports the proposed regulatory capital rules but urges the agencies to adopt specific recommendations from the ITFA/IACPM joint response. They argue that the final rules should recognize well-capitalized credit insurance providers as eligible guarantors to facilitate risk management and portfolio diversification.
Read comment → - Jun 18, 2026Secured Finance NetworkOpposeTrade association📎 Attachment
The Secured Finance Network (SFNet), a trade association representing financial institutions in asset-based lending, opposes the proposed rules because they fail to recognize the risk-mitigating value of nonfinancial collateral like receivables and inventory. They argue that the proposal will increase capital costs, discourage banks from providing vital working capital to small and medium-sized businesses, and ultimately harm the U.S. economy.
Read comment → - Jun 18, 2026Prime Mover InstituteSupportAdvocacy📎 Attachment
The Prime Mover Institute, a public interest organization, supports the proposed rule as a step toward objective, risk-based banking and ending "debanking" practices. They argue that the rule should include specific guardrails to prevent banks from using biased climate risk assessments to unfairly increase capital costs for energy-intensive industries.
Read comment → - Jun 18, 2026International Capital Market Association (ICMA) and International Securities Lending Association (ISLA)SupportAdvocacy📎 Attachment
The International Capital Market Association (ICMA) and the International Securities Lending Association (ISLA) submitted a joint comment supporting the recognition of modular, cross-product netting architectures within the Basel III Endgame framework. They argue that recognizing these existing industry-standard frameworks (like the CPMA) will preserve operational efficiency, accurately reflect net economic exposures, and maintain liquidity in the securities finance markets.
Read comment → - Jun 18, 2026BlackRock, Inc.SupportBusiness📎 Attachment
BlackRock, Inc. supports the proposed revisions to the U.S. capital framework to enhance risk sensitivity and transparency while aligning with Basel standards. However, they recommend specific adjustments to the risk-weighting of closed-end funds, business development companies, and high-quality project finance to avoid imposing undue costs or inhibiting financial intermediation.
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 improving the capital treatment of mortgage-related assets. They argue the rules better align capital requirements with risk, specifically praising the LTV-based risk weight approach and the elimination of capital deductions for mortgage servicing assets.
Read comment → - Jun 18, 2026The Coalition for Derivatives End-UsersOpposeAdvocacy📎 Attachment
The Coalition for Derivatives End-Users, representing 94 companies and municipalities, opposes the proposed capital requirements because they impose undue costs on commercial hedging and create regulatory redundancies. They specifically argue for exemptions for commercial end-users from CVA risk capital requirements and the retention of the SA-CCR alpha multiplier to maintain a competitive advantage for U.S. firms.
Read comment → - Jun 18, 2026Committee on Capital Markets RegulationSupportAdvocacy📎 Attachment
The Committee on Capital Markets Regulation, an independent research organization, broadly supports the proposed Basel III "finalization" reforms to improve the alignment of capital requirements with bank risks. They argue that the proposals will enhance the ability of banks to support U.S. financial markets and the real economy while maintaining a resilient capital framework.
Read comment → - Jun 18, 2026Arch Capital Group Ltd.SupportBusiness📎 Attachment
Arch Capital Group, Ltd. supports the proposed risk-based capital requirements but argues that the current proposals fail to sufficiently recognize the loss-mitigating benefits of private mortgage insurance (MI). The company advocates for specific amendments that allow banks to recognize MI coverage (subject to a counterparty haircut), permit insurance-based credit risk transfer (CRT), and lower risk weights for prudentially regulated eligible guarantors to improve bank participation in the mortgage market.
Read comment → - Jun 18, 2026Cboe Global MarketsSupportBusiness📎 Attachment
Cboe Global Markets expresses support for the proposed revisions to the regulatory capital framework, particularly the exclusion of derivative exposures from client clearing from the CVA capital charge and the allowance for netting certain contracts. However, the organization requests further revisions to allow the decomposition of index and ETF options to avoid unnecessary capital charges for market makers.
Read comment →