On July 27, 2023, the FDIC, Federal Reserve and OCC proposed new capital requirements for banks with more than $100 billion in assets. The proposal would implement the so-called "Basel III endgame" standards while eliminating the practice of relying on banks’ internal risk models. If implemented, the new rules would go into effect over three years starting on July 1, 2025. The deadline for public comments on the proposal was January 16, 2024. ABA opposes these requirements. Read our joint comment letter here.
Top regulators have put forward some dangerous misconceptions in their attempts to justify the Basel III endgame rule.
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ABA, other trade associations, and advocacy groups including the NAACP and the National Urban League are raising concerns that higher capital requirements will make it harder for banks to offer mortgages, particularly to first-time homebuyers. Regulators must carefully consider these implications before moving forward with a final rule.
If these standards are adopted, they will have a devastating impact on our efforts to increase Black homeownership and disadvantage all first-time, and, in particular, first-generation homebuyers who do not have the benefit of multi-generational wealth or higher than average incomes.”
— Housing Groups Letter (July 24, 2023)
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ABA President and CEO Rob Nichols, BPI President and CEO Greg Baer, and other subject matter experts discussed the associations' joint comment letter on regulators' Basel III proposal and took questions from members of the media.
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ABA Senior Vice President Hugh Carney spoke at a panel discussion on bank capital standards, following remarks by Fed Vice Chair for Supervision Michael Barr on the Basel III endgame proposal.
“A core strength of our current bank regulatory framework is risk-based tailored regulation. Today’s proposal represents a reversal of this longstanding approach.”
— Michelle Bowman, Federal Reserve Board of Governors (July 27, 2023)
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Hugh Carney
Executive Vice President, Financial Institution Policy & Regulatory Affairs
Regulatory Policy
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