Final rules implementing the Basel III international capital accord were adopted in July 2013, following extensive advocacy by banks, state bankers associations and every state banking regulator. The grassroots input helped to shape the final rules to ease the burden on banks, particularly community banks.
Action Alert! ABA is urging Subchapter S banks to write to federal regulators asking them to remedy a captail conservation buffer provision in the Basel III capital standards that would force S bank shareholders to pay taxes on undistributed income. ABA has posted a sample letter to help banks make the case for correcting this provision, which puts S Corps at a disadvantage to C Corps. Send a letter now
ABA believes additional adjustments to the final Basel III rules are needed to ensure the regulations work for banks of all sizes and do not impede economic growth. For example, ABA has advocated changes that would allow S corporation banks whose capital levels are not above the new required capital buffers to make limited distributions to shareholders in order to pay taxes due on the banks’ earnings.
ABA Staff Analysis
- ABA Comment Letter to FDIC Re Basel III, November 12, 2013
- ABA Mutual Banks Comment Letter on Basel III, October 25, 2012
- ABA, SIFMA, and FSR Comment Letter on Basel III, October 22, 2012
- ABA Supplement to Joint Trades Basel III Letter, October 22, 2012
- MBSD Supplement to Joint Trades Letter on Basel III, October 22, 2012
- FSR and ABA S&L Holding Company Letter in Basel III, October 22, 2012
- Link to other letters filed with the Agencies