-: Overall, I'm still not hearing a convincing justification
for adopting Basel III Endgame.
This was a process that started over a decade ago really,
and was focused on credit, operational, and market risk.
It has nothing to do with Silicon Valley Bank.
Silicon Valley Bank, you know,
the key attributes there were interest rate risk
and liquidity risk, and it really seems
like it's recommending knee surgery for a wrist injury.
It's just not really on point.
As they move forward, I am encouraged that there'll be a lot
of detail about the holistic review in the proposals.
However, I would encourage the Fed to issue separately
the holistic review for comment.
The stakes are high here, so it's very,
very important to get it right.
And since 2016, ABA has been advocating
for an advanced notice of proposed rulemaking
because there's a lot of complexities
of how these standards could be adopted in the US.