SIA Submits Comments to the Federal Reserve System on the Basel Capital Accord
The Securities Industry Association (SIA)* provides comments to the Board of Governors of theFederal Reserve System on the Basel Capital Accord. SIA believes there are a few key modifications and clarifications that can address the concerns we identify and foster a risk-based capital regime appropriate for commercial banks and investment banks alike. SIA suggests an internal models-based approach to calculatingrisk capital is more effective at estimating risk for many credit sensitive assets than the weightings-based approach for banking book assets under Basel II.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.