Public Comment AC96 Risk Based Capital Guidelines, Mortgage Insurance Companies of America

March 26, 2007 Office of the Comptroller of the Currency 250 E Street, SW Mail Stop 1-5 Washington, DC 20219 Docket Number 06-15 Via email to regs.comments@occ.treas.gov Suzanne C. Hutchinson Jennifer J. Johnson Executive Vice President Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551 Docket No. R-1238 Via email to regs.comments@federalreserve.gov Robert E. Feldman Executive Secretary Attention: Comments/Legal ESS Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429 RIN 3064-AC96 Via email to Comments@FDIC.gov Regulation Comments Chief Counsel's Office Office of Thrift Supervision 1700 G Street, NW Washington, DC 20552 Attention: No. 2006-49 Via email to regs.comments@ots.treas.gov RE: Risk-Based Capital Guidelines; Capital Adequacy Guidelines; Capital Maintenance: Domestic Capital Modifications Ladies and Gentlemen: The Mortgage Insurance Companies of America (MICA) are pleased hereby to comment on the agencies’ notice of proposed rulemaking (NPR) on the revisions to risk-based capital generally known as Basel IA. Aspects of this comment parallel views we provided on the accompanying Basel II NPR, with some comments and data duplicated here because of their relevance also to this proposal. We have gone into considerable depth on several of the questions asked about the proper risk-based ...