• ACB strongly supports risk buckets based on loan-to-value ("LTV") ratios for one-to-four family residential mortgage loans.
  
  
• The risk criteria such as LTV ratios and the number of units per loan should be taken into account to differentiate multifamily residential mortgages.
  
  
• Lower risk weights should be provided for commercial real estate loans that meet certain conditions, such as compliance with appropriate underwriting standards and the presence of an appropriate amount of long-term borrower equity.
  
  
• ACB supports the use of credit ratings as a factor in determining the risk of commercial loans and urges the agencies to allow banks to use additional types of collateral and LTV ratios when no credit rating exists.
  
  
• The collateral value for automobile and other secured consumer loans should be taken into account to differentiate these loans by LTV ratios.
  
  
• ACB supports a lower risk-weight for small business loans that have lower LTV ratios based on the value of eligible collateral, no defaults and full amortization over a seven-year period.
  
  
• ACB supports greater use of collateral and guarantees to reduce the capital requirements for exposures.
  
  
• The agencies should consider developing, or encouraging third parties to develop, a simplified risk-modeling system that could be used by less complex banks to establish risk-based capital requirements
  
  
• Depository institutions of any size that would prefer to remain subject to Basel I as it currently exits should have the option to do so.
  

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