Tag: Basel III

Coalition Urges Regulators to Refine Basel III Proposal for CRE Lending

Posted on by abigail_grenadier

The Real Estate Roundtable (RER) and a coalition of national real estate organizations urged federal banking regulators this week to make targeted refinements to the revised Basel III Endgame proposal to better calibrate capital rules for commercial and residential real estate lending. (Letter, June 18)

Why It Matters

  • In March, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) unveiled a substantially revised Basel III Endgame proposal, replacing the 2023 framework that drew broad industry opposition. (Reuters, June 18)
  • The coalition commended regulators for improving the revised proposal, particularly by tailoring capital requirements more closely to risk across different assets and activities, but warned that additional changes are needed to avoid unnecessarily constraining CRE credit. (Letter, June 18)
  • Commercial and multifamily real estate is a roughly $20 trillion sector supported by more than $6.4 trillion in debt, with approximately $3 trillion in CRE loans maturing over the next five years.
  • For commercial real estate, the reset could ease regulatory pressure that threatened to constrain credit for real estate lending, mortgage activity, and other capital-intensive transactions. (Roundtable Weekly, March 20)
  • “The Proposals significantly improve on the 2023 proposal,” the coalition wrote, adding that targeted refinements would “better calibrate CRE capital requirements without unduly constraining the financial system or burdening housing providers.”

Policy Priorities

  • The coalition urged regulators to better align capital treatment with actual risk for CRE exposures, multifamily loans, securitizations, warehouse facilities, mortgage servicing rights, Low-Income Housing Tax Credit (LIHTC) investments, and Fannie Mae Delegated Underwriting and Servicing (DUS) exposures.
  • The letter also recommends avoiding structural penalties for common CRE financing arrangements, including mezzanine loans, preferred equity, B-notes, junior participations, and loans involving special-purpose entities. (Letter, June 18)
  • Capital rules that are not properly calibrated could increase borrowing costs, reduce bank lending capacity, and constrain credit for housing development and other income-producing real estate.

Roundtable Advocacy

  • The Real Estate Roundtable (RER) has consistently opposed the original Basel III proposal, citing its potential negative impact on available credit capacity for commercial real estate transactions, market liquidity, and economic growth. (Roundtable Weekly, Nov. 2023 | Jan. 2024 |  Mar. 2024 | Dec. 2025 | Feb. 2026 |  March 20, 2026)
  • Earlier this year, federal regulators released a substantially revised Basel III proposal that reduced capital requirements for the largest U.S. banks by 2.4% overall and lowered certain risk weights for mortgages and mortgage servicing assets. (Financial Times, June 17)
  • In its June letter, the coalition urged regulators to preserve the proposal’s improvements while making targeted refinements to avoid unnecessarily constraining CRE lending, affordable housing investment, or broader economic growth. (Letter, June 18)

RER will continue working with policymakers, regulators, and real estate industry partners to support capital rules that are appropriately calibrated, risk-based, and aligned with the need for a stable and liquid commercial real estate finance market.

Federal Regulators Release Revised Basel III Endgame Proposal

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The Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) on Thursday unveiled a substantially revised Basel III Endgame proposal, replacing the 2023 framework that drew broad industry opposition. (WSJ | Fed Board Memo, March 19)

State of Play

  • The revised proposal would reduce capital requirements for the largest U.S. banks by 2.4% overall. (PoliticoPro, March 19)
  • The package would also replace the dual-track capital framework for the largest banks with a single approach, revise the G-SIB surcharge, and lower risk weights for mortgages and mortgage servicing assets. (ABA Banking Journal, March 19)
  • Regulators said the changes are intended to align capital with risk better, preserve safety and soundness, and support lending and other financial intermediation activities across economic conditions. (Fed Board Memo, March 19)
  • The interagency proposal would raise capital requirements by an estimated 1.4% under the revised Basel framework, but that increase would be more than offset by a 3.8% reduction in the G-SIB surcharge for the largest U.S. banks, for a net 2.4% decline overall.
  • Midsize banks would be allowed to decrease their capital buffers by an average of 5.2%, including stress-test revisions, and smaller banks by 7.8%. (WSJ, March 19 | AAF, March 20)
  • Regulators said the revised framework would also better support traditional lending and reduce incentives for activity to migrate outside the regulated banking system, including through lower risk weights for mortgages and mortgage servicing assets. (OCC News Release, Mar. 19)

Why It Matters

  • For commercial real estate, the reset could ease regulatory pressure that threatened to constrain credit for real estate lending, mortgage activity, and other capital-intensive transactions.
  • “Lowering the amount of capital held by banks would give them more money to deploy into the economy, potentially boosting growth,” said Federal Reserve Vice Chair for Supervision Michelle Bowman, who led the central bank’s efforts to craft the proposal. (Fed Press Release, March 19)
  • House Financial Services Committee Chairman French Hill (R-AR) and Subcommittee on Financial Institutions Chairman Andy Barr (R-KY) said the agencies had moved toward a “more balanced Basel III framework,” adding that right-sized capital standards are critical to preserving lending capacity, competitiveness, and access to credit. (Reps. Hill, Barr Statement, March 19)

Roundtable Advocacy

  • The Real Estate Roundtable (RER) has consistently opposed the original Basel III proposal, citing its potential negative impact on available credit capacity for commercial real estate transactions, market liquidity, and economic growth. (Roundtable Weekly, Nov. 2023; Jan. 2024; Mar. 2024)
  • In December, RER and a coalition of leading business trade organizations urged prudential regulators to examine and modernize large bank capital requirements so they continue supporting consumers, businesses, and the broader U.S. economy. (Letter, Dec. 2) (Roundtable Weekly, Dec. 5)
  • The coalition letter underscored the negative economic impacts of inappropriately calibrated capital rules, highlighted risks to American competitiveness, and commended ongoing agency efforts to improve the framework. (Roundtable Weekly, Feb. 20)

The agencies will accept comments on the proposed rules until June 18, and RER’s Real Estate Capital Policy Advisory Committee (RECPAC) looks forward to members’ input as it prepares comments on the proposal.

The Fed Signals Capital and Liquidity Reforms as Basel III Endgame Work Continues

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The Federal Reserve is moving to recalibrate key elements of the U.S. bank capital and liquidity framework, including Basel III Endgame implementation and targeted mortgage-capital adjustments. The Fed’s Vice Chair for Supervision, Michelle Bowman, signaled this week that reforms should support market liquidity and credit availability while maintaining safety and soundness. (FinancialTimes, Feb. 16)

State of Play

  • Bowman told bankers at the ABA’s 2026 Conference for Community Bankers this week that the Fed will soon seek comment on two proposals to encourage banks to re-engage in mortgage origination and servicing, within the Basel framework. (Speech, Feb. 16)
  • Bowman pointed to a “concerning trend” of mortgage activity to nonbanks. She cited data showing banks originated roughly 60% of mortgages in 2008 and serviced roughly 95% of outstanding balances; by 2023, those figures had fallen to about 35% and about 45%, respectively. (HousingWire, Feb.16).
  • The mortgage capital discussion comes as the Trump administration seeks tools to bolster affordability and credit availability, including directing Fannie Mae and Freddie Mac to purchase $200 billion in mortgage-backed securities. (Reuters, Feb. 18)
  • “By creating a resilient mortgage market that includes robust participation from all types of financial institutions, we can deliver affordable credit and high-quality servicing to borrowers regardless of economic conditions,” Bowman said. (Speech, Feb. 16)
  • Bowman said the shift has implications for the banking industry, mortgage market stability, and consumers.

Basel III Endgame

  • In separate remarks on Feb. 19, Bowman said regulators are modernizing the “four pillars” of the capital framework—stress testing, supplementary leverage ratio (SLR), Basel III Endgame, and the G-SIB surcharge—with a focus on market liquidity and affordable homeownership alongside safety and soundness. (Speech, Feb. 19)
  • Bowman said the Basel effort is “bottom-up,” not “reverse engineered,” arguing that finalizing Basel III would reduce uncertainty and provide clarity for bank capital standards. (PoliticoPro, Feb. 19)
  • The Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) recently submitted their Basel-related proposals to the Office of Management and Budget (OMB) for review—an important step in the interagency process. (Reuters, Feb. 13)
  • The Trump administration regulators have said they plan to rewrite liquidity rules, though details have not been released. (PoliticoPro, Feb. 19)
  • Bowman’s recent remarks are the clearest signal yet of how the Fed may recalibrate the U.S. approach to Basel capital implementation, following industry concerns that earlier proposals could constrain credit and further shift activity to less-regulated lenders.

Roundtable Advocacy

  • In December, RER and a coalition of leading business trade organizations urged prudential regulators to examine and modernize large bank capital requirements so they continue supporting consumers, businesses, and the broader U.S. economy. (Letter, Dec. 2)
  • The coalition letter underscored the negative economic impacts of inappropriately calibrated capital rules, highlighted risks to American competitiveness, and commended ongoing agency efforts to improve the framework. (Roundtable Weekly, Dec. 5)

What’s Next

  • The Fed is expected to issue the mortgage-capital proposals for public comment before any changes take effect, while agencies continue advancing a revised Basel III Endgame package.
  • Bowman is expected to testify next Thursday alongside the heads of the OCC, the FDIC, and the National Credit Union Administration at a Senate oversight hearing. (WSJ, Feb. 19)

As regulators advance both targeted mortgage capital adjustments and a revised Basel III Endgame proposal, RER will remain engaged to ensure capital reforms do not constrain credit flows essential to commercial real estate, economic activity, and long-term investment, while protecting safety and soundness.

Fed Cuts Rates Again Amid Split Outlook; Hearing Targets Capital Rules

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The Federal Reserve on Wednesday cut its benchmark interest rate by 25 basis points for the third straight meeting, lowering the federal funds target range to 3.50-3.75 percent. Fed Chair Jerome Powell emphasized that while policy is easing, the bar for additional reductions in early 2026 remains high.

Fed’s Decision

  • The Federal Open Market Committee (FOMC) vote was 9-3, with two policymakers preferring to hold rates steady and one seeking a deeper cut. (CNBC, Dec. 10)
  • Chair Powell said policy is “well positioned,” but stressed decisions are not on a preset path, citing mixed inflation signals and slowing but still resilient labor conditions. (Watch Press Conference)
  • The Chair noted that the latest projections show only one rate cut expected in 2026, signaling a potential pause in additional easing absent clearer labor and inflation trends.
  • Officials highlighted labor market softening as a key factor, with Chair Powell acknowledging it’s a “labor market that seems to have significant downside risks,“ even as inflation remains elevated.
  • He also expressed some optimism about growth, with the FOMC raising its outlook for 2026 GDP by half a percentage point, to 2.3 percent. (CNBC, Dec. 10)

Housing and CRE Outlook

  • Rate cuts alone won’t materially reprice CRE, as valuations and returns depend on multiple factors beyond monetary policy, and CRE has historically performed well even in higher-rate environments, industry analysts noted. (Connect CRE, Dec. 10)

  • Multifamily and industrial have already benefitted from the current rate environment, with multifamily development borrowing costs falling from 7.5-9 percent to ~6-7.25 percent and industrial cap rates expected to compress modestly. (Connect CRE, Dec. 10)

  • Commercial Mortgage-Backed Securities refinancing challenges remain acute, as lenders are unwilling to extend maturities without new borrower equity or substantive restructuring proposals. (Commercial Observer, Dec. 10)

Congressional Oversight & Capital Framework

  • At a House Financial Services Subcommittee hearing Thursday, witnesses largely urged regulators to calibrate the emerging Basel III Endgame proposal to support competitiveness, credit availability, and economic growth. (Watch Hearing)
  • Andrew Olmem (Partner, Mayer Brown) emphasized that capital decisions are policy choices: “Improperly calibrated requirements can reduce credit, raise borrowing costs, and slow wealth creation.”
  • GOP leaders on the subcommittee stressed the need for a tailored, data-driven framework that avoids the “gold-plated” standards identified by the Basel Committee.
  • Subcommittee Chair Andy Barr (R-KY) stated that the initial Basel III Endgame proposal was “deeply flawed” and pointed out that it has received bipartisan criticism. (Rep. Barr Press Release, Dec. 11)  

RER Advocacy

  • Thursday’s hearing was the latest in a series of recent steps policymakers have taken toward re-evaluating bank capital requirements.
  • Last week, RER and a coalition of leading business trade organizations encouraged prudential regulators to adopt requirements for large banks that support consumers, businesses, and the broader economy. (Roundtable Weekly, Dec. 5)

RER will continue to advocate policies that protect the safety and soundness of our financial system without harming credit flows and capital formation vital for CRE.   

Regulators Signal Capital Relief as House Hearing Sharpens Focus on Bank Requirements

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The House Financial Services Committee held an oversight hearing this week on prudential regulators, as federal agencies continue to reassess large bank capital standards. Ahead of the hearing, The Real Estate Roundtable (RER) and a coalition of business organizations urged regulators to modernize capital requirements to support lending, investment, and U.S. competitiveness.

House Financial Services Committee Hearing

  • Ahead of Tuesday’s hearing, Sen. Jerry Moran (R-KS) led a letter urging regulators to design the Basel III Endgame and GSIB Surcharge proposals to consider policies that would limit the adverse effects of disincentivizing banks from offering hedging products to industries sensitive to price volatility in commodity markets. (PoliticoPro, Dec. 2)
  • Federal Reserve Vice Chair for Supervision Michelle Bowman testified that regulators are not seeking to keep the “overall level of capital in the banking system the same,” leaving open the possibility that requirements may be reduced. (PoliticoPro, Dec. 2)
  • Trump-appointed regulators are negotiating a revised proposal to implement international Basel standards agreed to in 2017. The Biden-era draft would have significantly raised capital requirements and faced strong industry opposition. Earlier comments from Fed and FDIC officials suggested a “capital neutral” approach—but Bowman’s testimony indicated the final outcome could allow for lower aggregate requirements. (PoliticoPro, Dec. 2)
  • During the hearing, Rep. Andy Barr (R-KY) pressed regulators on whether they intend to issue a revised Basel III proposal that “predetermines a capital-neutral outcome even if some risks continue to be over-capitalized.” (PoliticoPro, Dec. 2)

Roundtable Advocacy

  • Ahead of the hearing, RER and a coalition of leading business trade organizations urged prudential regulators to examine and modernize large bank capital requirements so they continue supporting consumers, businesses, and the broader U.S. economy. (Letter, Dec. 2)
  • The coalition letter underscored the negative economic impacts of inappropriately calibrated capital rules, highlighted risks to American competitiveness, and commended ongoing agency efforts to improve the regulatory framework. (News Release, Dec. 2)

Enhanced Supplementary Leverage Ratio (eSLR)

  • The FDIC, OCC, and Federal Reserve signed off on the final version of a rule that reduces the size of the capital buffer large banks must maintain against total assets—recalibrating the enhanced supplementary leverage ratio to better reflect post-crisis market conditions. (Reuters, Nov. 25; PoliticoPro, Nov. 26)
  • The final rule, largely unchanged from the June proposal, adds a new cap on subsidiary-level capital buffers, a shift regulators say will modestly reduce aggregate requirements. (Roundtable Weekly, June 27)
  • The rule takes effect April 1, with banks permitted to adopt the looser standards starting Jan. 1. The FDIC also approved a proposed rule to lower leverage requirements for smaller banks.
  • In August, RER and Nareit provided comments to the FDIC, Treasury, and OCC supporting key elements of the proposed eSLR adjustments. (Letter, August, 15)
  • These changes add momentum to broader efforts to recalibrate bank capital rules ahead of the Basel III Endgame proposal expected in the coming months. (PoliticoPro, Nov. 26)

As regulators continue work on a revised Basel III Endgame proposal, RER will remain engaged to ensure capital reforms protect safety and soundness without constraining credit flows essential to commercial real estate, economic activity, and long-term investment.

Fed Cuts Rates Again as CRE Eyes Relief; Coalition Supports FSOC Reform

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The Federal Reserve on Wednesday approved a second consecutive quarter-point rate cut, lowering the federal funds rate to 3.75-4 percent. Chair Jerome Powell cautioned that another reduction in December is uncertain, suggesting the pace of easing could soon slow.

Fed’s Decision

  • The 10-2 vote saw Governor Stephen Miran favor a deeper half-point cut, while Kansas City Fed President Jeffrey Schmid opposed any reduction. (CNBC, Oct. 29)
  • Policymakers cited rising downside risks to employment amid persistent inflation near 3 percent.
  • Chair Powell noted “strongly differing views” on whether further easing is warranted, signaling a potential pause in December. “A further reduction in the policy rate at the December meeting is not a foregone conclusion. Far from it,” he said. (Watch Press Conference)
  • The chair also acknowledged the limited availability of economic data as the ongoing government shutdown has suspended federal data collection and reports.

Housing and CRE Outlook

  • At this week’s Fall Roundtable Meeting, House Financial Services Chair Rep. French Hill (R-AR) noted that persistent inflation continues to weigh on markets, though gradual rate cuts are beginning to ease conditions for housing and credit.
  • Continued monetary easing and the Fed’s balance sheet pivot may still bring modest relief to mortgage costs heading into 2026. (HousingWire, Oct. 29)
  • Economists note that improved credit conditions could stimulate purchase demand and support CRE transaction activity, though affordability challenges persist.

RER Advocacy

  • RER and coalition partners submitted a comment letter to the U.S. House of Representatives this week in support of H.R. 3682, the Financial Stability Oversight Council (FSOC) Improvement Act of 2025. (Letter, Oct. 28)
  • The bill, approved 47-4 by the House Financial Services Committee in Sept, would require FSOC to consult with a company and its primary regulator before designating a nonbank as a Systemically Important Financial Institution (SIFI), which would be subject to heightened prudential regulation and supervision by the Federal Reserve Board. (House Financial Services Committee Vote No. FC-198, Sept. 16)
  • The letter emphasized the importance of an activities-based approach to systemic risk, transparent cost-benefit analysis, and clear procedural guardrails to ensure predictability in financial oversight.
  • This follows a similar letter RER signed in July supporting efforts to restore due-process standards and coordination between FSOC and primary regulators. The letter urged FSOC to rescind its 2023 interpretive guidance and reinstate the Council’s 2019 framework for designating nonbank financial companies. (Letter, July 14)

Basel III Endgame

  • The Fed is circulating a revised Basel III Endgame proposal that would increase capital charges for large banks by 3-7 percent instead of the originally proposed 19 percent. (Bloomberg, Oct. 22)
  • RER strongly opposed the Fed’s original proposal, pointing out the significant economic costs it would incur without clear benefits to the economy, recommending that it be withdrawn and only reissued after further study. (Roundtable Weekly, June 27)

RER will continue to track developments on monetary policies and support measures that preserve liquidity and lending capacity as rate relief remains gradual.

Fed Chair Powell Testifies on Monetary Policy Outlook, Proposal to Ease Bank Capital Requirements, and Basel III Endgame

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In a busy week for Fed policy, Federal Reserve Chair Jerome Powell delivered his semiannual monetary policy report to Congress, testifying at a pair of House and Senate hearings on the state of the U.S. economy. Powell also fielded questions from policymakers on a new proposal unveiled this week to ease capital requirements for large banks and the state of Basel III Endgame.

Policy Outlook

  • In testimony before the House Financial Services Committee and Senate Banking, Housing, and Urban Affairs Committee, Chair Powell defended the Fed’s decision to hold interest rates steady last week. (Roundtable Weekly, June 20)

  • With consumer confidence weakening and inflation risks from tariffs and Middle East tensions rising, the Fed faces competing pressures that could challenge price stability.
  • On Capitol Hill this week, Chair Powell reiterated the Fed’s wait-and-see approach, saying, “For the time being, we are well positioned to wait to learn more about the likely course of the economy before considering any adjustments to our policy stance.” (Federal Reserve, June 24)
  • Two Trump-appointed Fed officials, Vice Chair for Supervision Michelle Bowman and board member Christopher Waller, signaled support for cutting interest rates as soon as July. Their public stance diverges from the majority of Fed officials, seven of whom do not anticipate any rate cuts this year, highlighting an unusual divergence among Fed leadership. (Axios, June 24)

The Fed’s New Proposal

  • On Wednesday, the Fed advanced a proposal to reform the enhanced supplementary leverage ratio (SLR) in a 5-2 vote, which would reduce capital requirements for relatively low-risk assets, like U.S. Treasury markets. (Reuters, June 25)
  • The SLR was originally designed as a backstop to risk-based capital requirements to ensure that large banks hold a sufficient amount of capital, regardless of the riskiness of those assets. (ABA Journal, June 23)
  • Sen. Tim Scott (R-SC), Chair of the Senate Banking, Housing, and Urban Affairs Committee, noted at the Senate hearing with Chair Powell, the backstop has “too often” acted as a binding requirement for U.S. banks, which could harm the effective functioning of U.S. Treasury markets during periods of distress and discourage banks from engaging in low-risk activity.
  • The proposed modifications are intended to make it less expensive for large banks to hold less risky assets, so that more capital is freed up for banks to invest in Treasuries and other low-risk markets.

  • Vice Chair Bowman touted the proposal as an “important first step in balancing the stability of the financial system and Treasury market resilience, while preserving safety and soundness and restoring the SLR as a backstop.” (PoliticoPro, June 25)

  • Chair Powell similarly highlighted the benefits of the reform proposal, noting that “it will not in any way diminish the safety and soundness of the financial system.” (Senate Hearing, June 25)

  • The Fed published a notice of proposed rulemaking on the proposal, opening it for public comment.
  • RER plans to comment on the proposal and its implications for the commercial real estate industry.  The organization’s Real Estate Capital Policy Advisory Committee (RECPAC) is working on a response to the notice of proposed rulemaking and welcomes member input.

Basel III Endgame

The Federal Reserve in Washington, DC
  • Chair Powell was also asked about the Fed’s plans for Basel III Endgame, which stalled after the proposal was met with widespread criticism from policymakers and industry associations last year.

  • Chair Powell told policymakers that the Fed would take a “fresh start” at Basel III in light of the feedback it received. He agreed that the original proposal’s capital requirements were excessive and “very significantly exceeded” the Basel requirements, suggesting that it will be further revised. (American Banker, June 25)

  • RER strongly opposed the original Basel III proposal, pointing out the significant economic costs it would incur without clear benefits to the economy, recommending that it be withdrawn and only reissued after further study.
  • Bowman, the newly appointed Vice Chair for Supervision at the Federal Reserve, is actively involved in reviewing and potentially reforming the Basel III endgame proposal to make it more capital-neutral for U.S. banks.
  • Tighter capital requirements and higher costs would come at a time when the commercial real estate industry is facing a wave of maturing loans, undermining the ability of owners and developers to restructure debt and fill the equity gap. So it is important for the Agencies to recalibrate their proposal accordingly to avert increased borrowing costs and reduced credit capacity for real estate and the overall economy.

Chair Powell’s term at the Fed isn’t up until May 2026—but reports indicate that President Trump is considering announcing his pick to succeed Powell far in advance, potentially a candidate who is more amenable to lowering interest rates on an accelerated timeline.

RECPAC Fall Meeting Spotlights Upcoming Policy Opportunities and Challenges in Real Estate Capital Markets

Posted on by Trey Jackson

The Real Estate Roundtable’s Real Estate Capital Policy Advisory Committee (RECPAC) convened this week in New York to address market conditions, pressing policy issues, including Basel III Endgame, shifts in capital markets, and the evolving political and regulatory landscape.

Fall RECPAC Meeting

  • RECPAC met Tuesday, under the leadership of RECPAC Co-Chairs Bryan McDonnell (Head of U.S. Debt and Chair of Global Debt, PGIM Real Estate), Rex Rudy (EVP, Head of Commercial Real Estate, US Bank), Miriam Wheeler (Global Head Real Estate Finance, Goldman Sachs Asset Management), and Working Group Chair Michael Lascher (Global Head of Real Estate Debt Capital Markets, Blackstone) to discuss the new political landscape and top policy priorities for 2025.
  • Roundtable Chair Kathleen McCarthy (Global Co-Head, Blackstone Real Estate) kicked off the meeting and welcomed RECPAC members to the meeting, sharing her insights on real estate credit and capital markets. Other discussions included:
  • Overview of Real Estate Capital Markets: Mark Gibson (CEO, JLL Capital Markets, Americas) provided an overview of current economic and real estate market conditions, investment capital flows, interest rate trends, and their impact on financing.
  • Political and Regulatory Landscape: Wayne Berman (Head of Government Affairs, Blackstone) discussed the new political landscape, and its implications for financial services and tax policy, credit, and capital market issues.
  • U.S. Economic Outlook: David Mericle (Chief US Economist, Goldman Sachs) presented his views on the U.S. economic outlook, including growth prospects and recession risks.
  • Global Real Estate Credit Markets Roundtable: Nick Seidenberg (Managing Director, Eastdil) led a discussion on global real estate credit markets, joined by Jeff Krasnoff (CEO, Rialto Capital), Bryan McDonnell (Chair, Global Debt and Agriculture, PGIM), Rex Rudy (EVP, U.S. Bank), Miriam Wheeler (Global Head, Real Estate Financing, Goldman Sachs), and Greg Wolkom (Group Head, Real Estate Syndicated Finance and REIT Finance, Wells Fargo).

Committee on Foreign Investment in the U.S (CFIUS)

  • This week, the U.S. Department of the Treasury, as Chair of the Committee on Foreign Investment in the United States (CFIUS), finalized a previously proposed rule expanding both the types of military installations covered by its regulations governing reviews of real estate transactions and the number of military installations subject to those reviews. (Axios, Nov. 18)
  • Under the proposed rule issued in July, foreign land transactions within a mile of 40 additional military installations and within 100 miles of 19 additional military sites would trigger a CFIUS review. (Roundtable Weekly, July 12)
  • The finalized rule, which impacts transactions entered into on or after December 9, 2024, continues the trend toward reviews of more real estate transactions based on their proximity to a growing list of military installations deemed “sensitive,” and also allows for greater growth by changing the definition of “military installations” that can become subject to these regulations in the future. (Morgan Lewis, Nov. 18)
  • Nearly 60 military installations will be added to an existing list of military installations and approximately 10 existing installations will be extended for CFIUS jurisdiction purposes.
  • During their annual conference this week, CFIUS mentioned that the renewable energy industry has been a particular area of focus triggering jurisdiction over real estate transactions, due to the critical infrastructure component. (The National Law Review, Nov. 20)

Basel III Endgame

Federal Reserve Vice Chair for Supervision Michael Barr
  • Barr, the Fed’s top regulatory official, said the central bank will not be moving ahead with its plan to hike capital requirements for big banks, also known as Basel III Endgame, or move on any proposals to overhaul rules affecting bank liquidity and long-term debt over the next two months. (Politico Pro, Nov. 20)
  • “I expect to work with my new colleagues at the OCC and the FDIC in the coming year on those measures to get their policy input, their perspectives,” Barr said.
  • Earlier this year, RER raised industry concerns about the negative impact of the Basel III proposal in a Jan. 12 letter to the Fed and other agencies. The comments outlined how the proposal would decrease real estate credit availability, increase borrowing costs for commercial and multifamily real estate properties, and negatively impact the U.S. economy, concluding with a call to federal regulators to withdraw their proposed rulemaking. (Roundtable Weekly, Sept. 19)
  • New regulators are expected to lead the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Consumer Financial Protection Bureau (CFPB) when President-elect Trump takes office in January 2025.

The Roundtable’s Real Estate Capital Policy Advisory Committee (RECPAC) will continue to engage with policymakers on any further changes to the Basel III Endgame proposal and other federal policy issues impacting credit capacity and capital formation.

Fed Revises Basel III Endgame Proposal

Posted on by Trey Jackson

Federal Reserve Vice Chair for Supervision Michael S. Barr previewed the latest revisions to the Basel III Endgame capital requirements this week. Amid industry opposition, Barr scaled back his initial proposal to raise capital requirements for large banks, offering a more measured approach to the rule. (Bloomberg, Sept. 10)

Basel III & CRE

  • The revised proposal would increase aggregate Common Equity Tier 1 (CET1) capital requirements for global systemically important banks by roughly 9%—half of what would have been required in the original proposal.
  • Banks with assets between $100 billion and $250 billion are now exempt from most of the proposed changes, except for recognizing unrealized gains and losses in regulatory capital. (Politico, Sept. 10)
  • “There are benefits and costs to increasing capital requirements,” Barr said during his September 9 remarks at the Brookings Institution. “The changes we intend to make will bring these two important objectives into better balance, in light of the feedback we have received.” (Barr’s Speech | Bloomberg, Sept. 10)
  • The proposal reduces risk weights for certain residential mortgages, and retail exposures, extending this reduction to low-risk corporate debt. However, commercial real estate risk weights remain unclear.
  • Non-GSIB banks would see a long-term increase of 3 to 4% in capital requirements, mainly from the inclusion of unrealized gains and losses. Other changes are expected to add just 0.5% to their capital obligations.
  • The Roundtable raised industry concerns about the negative impact of the Basel III proposal in a Jan. 12 letter to the Fed and other agencies. The comments outlined how the proposal would decrease real estate credit availability, increase borrowing costs for commercial and multifamily real estate properties, and negatively impact the U.S. economy, concluding with a call to federal regulators to withdraw their proposed rulemaking. (Roundtable Weekly, Mar. 29)

What’s Next

  • An open Board meeting is expected to be scheduled to review the revised plan, with an announcement expected as early as Sept. 19. The plan will be open to public comment for 60 days once released.
  • While this new proposal is an improvement of the original plan, we remain concerned that any increase in capital requirements will have a pro-cyclical impact on credit capacity and still carry a cost for commercial real estate and the overall economy.

The Roundtable’s Real Estate Capital Policy Advisory Committee (RECPAC) will continue to monitor and respond to any further changes to the Basel III Endgame proposal and other federal policy issues impacting credit capacity and capital formation.

Federal Regulators Signal Significant Changes for Proposed Bank Capital Hikes

Posted on by Trey Jackson
The Federal Reserve in Washington, DC

Proposed regulations that would dramatically hike capital requirements for the nation’s largest banks may undergo significant changes, which could include a 50 percent reduction in the current mandated increase, according to sources cited by The Wall Street Journal on May 19.

Proposed Capital Requirements

  • Top officials from the Fed are working with regulators from the Federal Deposit Insurance Corp. (FDIC) and the Office of the Comptroller of the Currency (OCC) on “negotiating substantive and technical revisions” to the current proposal, known as the “Basel III Endgame.” (WSJ, May 19)
  • The Real Estate Roundtable strongly opposes the current proposal, which would hike capital requirements by approximately 19 percent for banks with at least $100 billion in assets. (Roundtable Weekly, March 29)
  • Barclay estimates the proposal, if approved without changes, would require eight U.S. global systemically important banks to hold approximately $150 billion more in capital. (WSJ, May 23)

Roundtable Response

Real Estate Roundtable President and CEO Jeffrey DeBoer testifies before House Oversight Subcommittee on April 30, 2024
  • Roundtable President and CEO Jeffrey DeBoer testified this month before a House subcommittee on the health of CRE markets and offered Roundtable policy recommendations, which included rejection of the Basel III Endgame—along with other pro-cyclical regulatory measures that would restrict credit and capital formation. (Roundtable Weekly, May 3 | DeBoer’s oral statement and written testimony)
  • Additionally, a Jan. 12 Roundtable letter and Jan. 16 industry coalition letter urged federal banking regulators to withdraw the proposed rule, emphasizing its potential negative impact on available credit capacity for commercial real estate transactions, market liquidity, and economic growth. (Roundtable Weekly, Jan. 19)

Policymakers Signal Adjustments

Federal Reserve Vice Chair for Supervision Michael Barr
  • The proposal has been met by internal disagreement and concerns among the seven-member Fed Board. (Roundtable Weekly, March 29)
  • Michael Barr, the Fed’s Vice Chair for Supervision, said in a May 20 speech that the central bank is exploring “targeted adjustments” to bank liquidity rules, including Basel III.  In March, Fed Chairman Jerome Powell testified before congressional committees that he expects regulators to “make broad and material changes” to the Basel III proposal. (PoliticoPro, May 20 and Roundtable Weekly, March 8)

The Roundtable’s all-member Annual Meeting on June 20-21 in Washington, DC will address Basel III Endgame and other capital and credit issues impacting CRE.

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