On July 27, 2023, the federal banking regulators—the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Federal Reserve (the Fed)— jointly issued a proposed rule that would revise large bank capital requirements, named Basel III Endgame. In response, the AHTCC proposed to the regulators lowering the risk weighting of Housing Credit investments to 50 percent to more accurately reflect the risk associated with such investments, align with the weighting of multifamily mortgages, and support investment in affordable housing production.

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.

In addition to submitting a comment letter, the AHTCC co-led a broader industry letter alongside the National Association of Affordable Housing Lenders (NAAHL) that echoed the call to reduce the risk weighting for Housing Credit investments in the final rule.