The Bank Policy Institute, the American Bankers Association, the Financial Services Forum, the Institute of International Bankers, the Securities Industry and Financial Markets Association, and the U.S. Chamber of Commerce are writing with respect to your agencies’ jointly proposed rulemaking that would amend the capital requirements applicable to large banking organizations, and in particular to the agencies’ promised “quantitative impact study” of the proposal’s effects on bank capital requirements.
As the agencies have clearly acknowledged, this data collection and analysis is necessary to fully understand how much capital the proposed rule’s revised risk weights and other changes would require covered banks to hold, and thus is an essential prerequisite to the agencies properly and accurately weighing the relative costs and benefits of each aspect of the proposed rule and the rule as a whole.
