MBA Files Comment letter on Basel III

Yesterday MBA sent their comment letter on Basel III covering Regulatory Capital Rules:

A. Regulatory Capital, Implementation of Basel III: Minimum Regulatory Capital
Ratios, Capital Adequacy, Transition Provisions and Prompt Corrective Action
(Regulatory Capital Rule)

B. Standardized Approach for Risk-Weighted Assets: Market Discipline and
Disclosure Requirements (Standardized Approach)

C. Advanced Approaches Risk-based Capital Rule: Market Risk Capital Rule
(Advanced Approach)

The 84 page letter focused on issues in the following areas of real estate finance:

  • Impact on the Mortgage Market from Basel III
  • Mortgage Servicing Rights (both residential and commercial/multifamily)
  • Residential Mortgage Loans
  • Multi-family/Commercial Real Estate Loans
  • Securitization Exposures
  • Fannie Mae and Freddie Mac MBS (both residential and multifamily)
  • Commercial and Multifamily Servicer Cash Advance
  • Financing Independent Mortgage Companies
  • Off-Balance Sheet Exposure

MBA Basel III Comment Letter