SIFMA and The Clearing House Association, L.L.C. (TCH) provide comments to the Board of Governors of the Federal Reserve (Fed), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) on the joint agency notice of proposed rulemaking (NPR) to modify their respective Basel II-based Internal-Ratings-Based and Advanced Measurement Approaches for risk-based capital to be consistent with Section 171(b)(2) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The groups share concerns with respect to the agencies’ approach as set forth in the NPR, however, primarily focused on the interplay between amendments proposed in the NPR and other upcoming amendments in bank capital regulation, including Basel III.