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CBA whitepaper examines long-term impacts of Basel III Endgame proposal

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Banking, Industry Regulation
Tuesday, March 19, 2024

The Consumer Bankers Association (CBA) published a whitepaper examining various aspects of the federal banking regulators’ proposed Basel III capital risk management rules, describing how some of the proposed changes could be harmful to institutions and consumers.

The whitepaper highlights multiple regulatory changes within the proposal that would make it more expensive for banks to lend to retail consumers, therefore potentially benefitting non-bank lenders that are not subject to the same stringent capital standards. The report includes historical data describing periods in which regulated banking entities had difficulty competing with non-banks and the impact on consumers.

“Mortgage servicing provides a good example of how this shift to non-bank financial institutions plays out across retail products,” the report stated. “Mortgage servicing is the business of collecting mortgage payments, escrowing tax and insurance, maintaining accurate books and records, and working with homeowners who have fallen behind on their mortgage payments, and if necessary, taking foreclosure actions. When the regulatory agencies significantly increased the capital charge associated with this service, the relative amount of servicing conducted by banks dropped precipitously.”

CBA’s findings also point to possible negative lifelong effects on consumers’ financial health, resulting from the new capital standards, disproportionately impacting low-and moderate-income consumers, disabled consumers and Black and Hispanic populations. For example, some regulatory changes would make it more difficult for banks to extend credit cards to consumers, particularly those with rolling debt balances.

“Comparing credit cards and non-bank Buy Now, Pay Later products provides a useful example of the types of consumer protections that consumers may forgo when they opt for a non-bank financial product,” the report states. “In 2022, the CFPB (Consumer Financial Protection Bureau) published a report based on data from five non-bank Buy Now, Pay Later providers showing their rapid growth, but also highlighting a number of the risks they pose to consumers. The CFPB found that the five firms originated 180 million total loans totaling $24 billion in 2021 – a near tenfold increase in just two years.”

Recent research by the Federal Reserve Bank of Boston indicated that access to credit cards is a key factor enabling some college students to stay in school. However, this impact is limited to students working part time to pay for tuition or who rely on need-based financial aid. Similarly, the Federal Reserve Board reported that Black credit cardholders are nearly twice as likely to carry a balance on their credit cards as white cardholders. The same Federal Reserve Board study found that 57 percent of disabled cardholders said they carried a rolling balance, as opposed to 46 percent of non-disabled cardholders. 

Additionally, the report points to research conducted by the CFPB, which found that 45 percent of consumers in low-income neighborhoods lacked credit scores, compared to just 9 percent in upper-income neighborhoods, citing data collected via the Home Mortgage Disclosure Act (HMDA).

“The proposal asserts that regulators ‘are supportive of homeownership and do not intend the proposal to diminish home affordability or homeownership opportunities, including for low- and medium-income home buyers or other historically underserved markets,’” the report states. “Yet, the proposal’s increased risk weights will increase costs to consumers that need to borrow to purchase their homes. Further, the proposal creates a number of other important changes to how other mortgage-related commitments and pertinent hedging activities are treated that will disproportionately impact low- and moderate-income borrowers.

“To begin with, the proposal would materially increase the capital charge for low down payment mortgages that are protected by mortgage insurance. In some cases, the increase could be as much as 80 percent, due to the proposal’s 20 percent risk weight add-on to internationally agreed-upon standards. As a result, consumers who are not able to afford significant cash down payments of 20 percent, including many first-time homebuyers, and who need mortgages with greater than 80 percent loan-to-value ratios will find reduced availability of mortgages and higher costs for the mortgages that are available.”

Banks could also run into issues with Community Reinvestment Act (CRA) compliance as a result of the proposed changes as well.

“By limiting the ability for banks to provide low down payment mortgages, the 20 percent risk weight add-on would also make it more challenging for banks to fulfill their obligations under the Community Reinvestment Act,” the report argues. “The Community Reinvestment Act was amended just three months after the release of the proposal, specifically for the purpose of encouraging ‘banks to expand access to credit, investment, and banking services in low- and moderate-income communities.’”

By impacting consumer financial health, CBA argues the proposal could reinforce stubbornly pervasive headwinds in consumers’ broader lives and points to recent congressional testimony explaining that the proposals’ impact on consumer credit visibility and credit scores could even have detrimental effects on consumers’ lives outside of banking, including renting a home, getting a job or, in some cases, receiving medical services. 

Federal Reserve Chair Jerome Powell indicated the Basel III Endgame proposal will likely undergo “material and broad changes” during his recent testimony before the Senate Banking Committee.  

The full whitepaper can be found on CBA’s website here.

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