The Commercial Mortgage Securities Association and The Mortgage Bankers Association (MBA) filed a comment letter with banking regulators to address the proposed risk-based capital treatment of assets coming on the books of banks on January 1, 2010, as a result of FAS 166 and FAS 167.

FAS 166 and FAS 167 will require hundreds of billions of dollars of assets to come onto the banks’ balance sheets on January 1, 2010, which would immediately require an allocation of capital under the regulatory capital rules proposed.   

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