Letter: Supplemental Comment Letter to Banking Regulators on Basel III Endgame Proposed Rule

May 2, 2024

USMI submitted a supplemental comment letter to the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively the Agencies) in response to the Basel III Endgame Proposed Rule (Proposed Rule). In the letter, USMI requested that the Agencies clarify their intention to recognize private mortgage insurance (MI) as a part of the prudent underwriting criteria that determines whether a loan is a “regulatory residential real estate exposure” in the Proposed Rule, including eliminating a mischaracterization about the private MI industry. USMI also urged the Agencies to provide loan-level capital credit for high loan-to-value (LTV) mortgages with private MI coverage that is consistent with the Federal Housing Finance Agency’s Enterprise Regulatory Capital Framework and the GSEs’ Loan-Level Pricing Adjustments. Click here to read the full letter.