MBA Statement on the Banking Agencies’ Basel III Endgame Re-proposal

WASHINGTON, D.C. (March 19, 2026) — MBA's President and CEO Bob Broeksmit, CMB, released the following statement on the notice of proposed rulemaking (NPR) issued jointly by the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Federal Reserve:

“The federal banking agencies’ updated Basel III proposal represents a pivotal step toward a more balanced and risk-aligned approach to capital standards affecting mortgage lending and commercial real estate finance.

“Capital rules are notoriously complex, but based on our initial review, the re-proposal incorporates several priorities long advocated by MBA, including more risk-sensitive capital requirements using loan-to-value ratios and the opportunity to consider the recognition of credit enhancements such as private mortgage insurance. It also takes important steps to reduce the punitive treatment of mortgage servicing rights and commercial real estate loans.

“MBA will review the proposal closely and looks forward to engaging in the formal comment process, including on key technical elements such as the appropriate capital treatment of mortgage servicing assets and the broader application of these reforms across the banking system. We stand ready to work with the agencies on a final framework that better supports sustainable mortgage origination and warehouse lending, robust servicing capacity, and continued access to affordable home financing offered by both depositories and independent mortgage banks.”