Coalition Comment Letter to Federal Banking Regulators on Capital Standards for Housing Credit Properties in Amended Bank Capital Standards

In this letter, NCSHA joined 26 other housing advocacy organizations to comment on a series of Notices of Proposed Rulemaking (NPRs) issued by federal banking regulatory agencies — the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency — modifying the federal bank capital standards. The letter suggests the Regulators the lower the amount of capital banks are required hold on their books for Housing Credit investments and Housing Credit finance properties from 100 percent to 20 percent, and argues that they shouldn’t be set at a level above 50 percent.