MBA Joint Comment Letter on the Banking Agencies’ Basel III Endgame NPR (Impacts on CRT)
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The undersigned housing organizations, are united in our concern that the Basel III Endgame proposed rule, as currently drafted, will cause unintended harm to home loan borrowers by significantly increasing overall required capital and risk weights for mortgage assets held in portfolio by banks. To address this, in addition to other recommendations we may independently and separately make, we ask that your agencies modify your risk-based capital regulations so that it is clear banks can use reinsurance credit risk transfer (CRT) for risk mitigation and receive capital relief for using it.
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