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
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
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- Jun 18, 2026Asian Infrastructure Investment BankSupportAdvocacy📎 Attachment
The Asian Infrastructure Investment Bank (AIIB) supports the agencies' efforts to simplify risk-based capital regulations but requests that the AIIB be expressly included in the definition of "multilateral development bank" (MDB). They argue that the AIIB meets all the criteria for MDB status, including high credit ratings and strong shareholder support, and that its exclusion creates a competitive disadvantage for U.S. banking organizations.
Read comment → - Mar 30, 2026Sergio Federico Carrillo FarfanSupportIndividual📎 Attachment
Sergio Federico Carrillo Farfan, a financial risk management professional, supports the proposed ERBA framework as a pragmatic modernization of regulatory capital requirements. However, he argues that the proposal contains structural gaps regarding cross-border risk in the U.S.-Latin America corridor and recommends specific enhancements to account for FX mismatches, idiosyncratic market risks, and elevated BSA/AML model risks.
Read comment →