CBA Basel White Paper

The Consumer Bankers Association (“CBA”) is America’s only member-driven trade association focused exclusively on retail banking.1 Since 1919, CBA has partnered with member banks to promote sound policy, prepare the next generation of diverse bankers to lead the industry, and enable consumers’ individualized approaches to the American dream. 

In the summer of 2023, our nation’s prudential bank regulators proposed a sweeping set of new bank capital regulations, which would purport to implement an international agreement colloquially known as “Basel III Endgame” (the “Proposal”). Among other changes, the Proposal would substantially revise the “risk-based capital framework” for all banks with $100 billion or more in assets. 

The Proposal’s sweeping changes would have profound impacts on our members’ ability to serve their customers. While regulators acknowledge that the Proposal would impact different banks in different ways, we are concerned that the Proposal is not appropriately calibrated with respect to retail banking. Regulators similarly acknowledge multiple times in the Proposal that its changes may have detrimental impacts on consumers, making this overhaul an area of particular interest and concern for CBA. Despite the Proposal’s hundreds of pages, it contains no actual analysis of the specific impacts its regulatory changes will have on consumers, much less different groups of consumers. 

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