On March 19, 2026, the Federal Reserve, OCC and FDIC released their long-anticipated revised rulemaking known as the 'Basel III Endgame'. The 2023 draft triggered one of the most broadly opposed rulemakings in recent regulatory history, drawing opposition from banks, housing advocates, energy companies, and bipartisan majorities in Congress over concerns that its proposed capital increases would constrict credit and harm the economy.

 The new proposal, at a high level, appears to move toward lower overall capital requirements compared to the initial proposal and introduces greater risk sensitivity in how those requirements are calculated. This is a constructive development for lending activities broadly.

However, based on our preliminary review, the proposal does not appear to include specific recognition of non-financial collateral in the manner SFNet has consistently advocated for in our discussions with regulators. As a result, the capital treatment of asset-based lending does not yet explicitly reflect the structural risk characteristics and historical performance of the product.

Importantly, this is a proposal, and there will be an opportunity for comment and further advocacy. SFNet intends to engage actively in the comment process to continue advancing the case for appropriate recognition of asset-based lending and its underlying collateral.

SFNet is conducting a detailed review of the full 1,200-page proposal and will provide more comprehensive analysis, implications, and potential advocacy steps in the coming days.