Commercial Real Estate Sector Coalition Comment Letter to the OCC, FDIC & FRB Regarding NSFR

Issue Date: August 05, 2016


On August 5, 2016 NAR as part of Commercial Real Estate Sector Coalition sent a letter to the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Federal Reserve Board of Governors (FRB). The letter expressed concern about the impact that the Net Stable Funding Ratio (NSFR) requirement will have on commercialreal estate credit capacity – particularly in view of the overlapping financial regulatory changesunder Dodd-Frank Wall Street Reform and Protection Act (“Dodd-Frank”) and Basel III that are now beginning to manifest. The cumulative effect of these measures is that “market liquidity” 3 has been severely constrained and this may result in unduly diminished capital availability and economic growth.