ACORE Comments on the Basel III Proposal and Impacts on Tax Equity

The Honorable Michael S. Barr
Vice Chairman for Supervision
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue N.W.
Washington, DC 20551

The Honorable Martin J. Gruenberg
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington D.C. 2049-9990

Mr. Michael J. Hsu
Acting Comptroller of the Currency
The Office of the Comptroller of the Currency
400 7th Street, SW
Washington, D.C. 20219

Via Electronic Submission

RE: Regulatory Capital Rule: Amendments Applicable to Large Banking Organizations and to Banking Organizations with Significant Trading Activity. (Docket ID OCC–2023–0008; Docket No. R–1813; RIN 7100–AG64; RIN 3064–AF29).

Dear Vice Chair Barr, Chairman Gruenberg, and Acting Director Hsu:

The American Council on Renewable Energy (“ACORE”) respectfully submits these comments in response to the proposed Regulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading Activity. ACORE’s membership includes renewable energy developers, institutional investors, corporate buyers of renewable energy and environmental attributes associated therewithin, electric power generators, retail energy providers, and other stakeholders. ACORE member companies collectively hold $22 trillion in assets. In 2022, 90% of the booming utility-scale U.S. renewable growth was financed, developed, owned, or contracted for by ACORE members.