CONTACT: Barbara Hagenbaugh
(202) 457-8783
bhagenbaugh@fsforum.com
Highlighting Concerns on Basel III Endgame
Washington, D.C. – A number of individuals and organizations have raised concerns with the Basel III Endgame proposal. One week ahead of the comment deadline, we highlight some of those concerns that have been raised thus far in comment letters:
California Public Employees’ Retirement System (CalPERS)
“There are unintended consequences in the Proposal. … The Proposal would punish CalPERS – and its two million beneficiaries – because it does not issue publicly traded debt securities. That error should be remedied.”
American Farm Bureau Federation, National Council of Farmers, and other farm groups
“We are very concerned that any contraction in the availability of clearing services will have a disproportionate impact on agricultural end-users that are far outside the major financial centers, especially smaller entities such as grain elevators and family farms. We urge you to modify the proposals so that they do not disincentivize banks from providing this important service to their customers.”
Business Roundtable
“The impact of this proposal is understated and will impede the ability of America’s banks to provide a range of critical financial services to Business Roundtable member companies, reducing both innovation and economic growth.”
Committee on Capital Markets Regulation
“A more robust analysis is needed. As the Committee has previously argued, a rigorous cost-benefit analysis showing that the economic benefits of a proposed rule will outweigh its economic costs should be a prerequisite for rulemakings by federal regulatory agencies.”
Liberty Latin America
“The imposition of burdensome regulations on counterparties to commercial end-users, who are engaged in simple risk management, may have a significant negative impact on companies like ours, as we operate in the global economy. Because these large banking organizations act as capital markets intermediaries, sources of credit, underwriters of corporate debt and equity securities, and liquidity providers, the Proposals will adversely impact US banking institutions, as well as their end-users. Further, the discrepancies between the Proposals and those adopted by the EU and the UK create a scenario where commercial end-users may be compelled to conduct derivatives transactions with banking institutions beyond the regulatory scope of the US.”
Whalen Global Advisors Chairman R. Christopher Whalen
“This proposal reflects a view of financial risks facing US banks that is decades out of date and ignores the public record regarding bank failures.”
American Council on Renewable Energy, and other organizations
“The treatment of tax equity in the proposed capital requirements is both unwarranted and particularly detrimental to [Inflation Reduction Act]-incentivized projects.”
Go to smartbankcapital.com to learn more about the strength and resiliency of the nation’s largest banks and the costs of higher capital requirements.
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