Opposition and significant concerns dominate the record.

By Arthur S. Long, Roman Martinez, Pia Naib, and Jordan R. Goldberg

Key points:

  • Most commenters reacted negatively to the Proposal, with over 97% of comment letters either opposing it and calling for a re-proposal, or expressing substantial concerns with the Proposal or its critical aspects.
  • Opposition comes from a diverse array of domestic and international interests.
  • A significant majority of elected officials, both Democratic and Republican, joined comment letters expressing opposition to or serious concerns with the Proposal.

On July 27, 2023, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (together, the Banking Agencies) issued a comprehensive proposal (the Proposal) to overhaul the methods by which large banking organizations must calculate risk-based capital requirements.

In part, the Proposal’s stated purpose is to effectuate the so-called Basel III Endgame international capital standard endorsed by the Basel Committee on Banking Supervision. Public comments on the Proposal were originally due by November 30, 2023, but the deadline was extended to January 16, 2024.

This report provides an analysis of 356 comment letters that the Banking Agencies received and made available to the public through January 24, 2024, focusing on institutional commenters; comments by national, community, and organizational leaders; and substantive comments by individuals.

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