The U.S. Basel III Endgame Reproposal: Analysis Of The Securitization Framework

On March 19, 2026, the Federal Reserve, the OCC, and the FDIC issued three concurrent notices of proposed rulemaking (collectively, the “Reproposal”) that would substantially revise the risk-based capital framework for U.S. banking organizations. The Reproposal would, among other things, (1) introduce a new “expanded risk-based approach” (“ERBA”) for calculating risk-weighted assets that would be mandatory for Category I and II banking organizations and available on an opt-in basis for other banking organizations, and (2) revise the standardized approach applicable to all other banking organizations (other than those using the CBLR framework).

The whitepaper focuses on the securitization framework under both ERBA and the revised standardized approach. The Reproposal would replace the current bifurcated securitization capital framework (which uses SSFA and the gross-up approach under the standardized approach, and SFA under the advanced approaches) with a single methodology, SEC-SA,