Today the AHTCC submitted comments to the Federal Reserve Board of Governors, Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) in response to the agencies’ Notice of Proposed Rulemaking (NPR) on regulatory capital rule amendments applicable to large banking organizations and to banking organizations with significant trading activity, or Basel III Endgame.
The AHTCC’s comments urged the banking regulators to apply a lower risk weight of 50 percent to Low-Income Housing Tax Credit (Housing Credit) properties. Given that banks provide approximately 85 percent of all Housing Credit equity investments, bank capital rules have a material effect on the availability and pricing of Housing Credit investments. The AHTCC’s comments further outline how a lower threshold is consistent with what is available to statutory multifamily mortgages, more accurately reflects the risks of LIHTC investment, and would support investment in affordable housing at a time of staggering need.
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