SIFMA, the American Bankers Association (ABA) and the Financial Services Roundatable (FSR) provide comments to multiple federal agencies on proposals to comprehensively revise the regulatory capital framework for U.S. banking organizations.

To ensure the proposed bank capital standards strengthen the U.S. banking system, without harming the economy or the ability of banks to serve their customers, the Associations respectfully recommend that:

• The Agencies should withdraw the Standardized Approach NPR to address its many problems and any re-proposal should be simplified and easier to follow and implement;

• The Agencies should conduct an empirical study of the impact on the U.S. banking system and bank customers resulting from the changes proposed to the current risk weight framework in the Standardized Approach NPR, the capital components of the Basel III Numerator NPR, and changes to the treatment of counterparty credit exposures in the Advanced Approaches NPR; and

• No banking organization should be required to comply with any changes to the existing bank capital framework sooner than one year after a final rule is published in the Federal Register. Moreover, additional time for compliance should be provided to community banks and savings and loan holding companies to allow them to adapt systems and access the capital markets as necessary in an orderly fashion and, in any event, the effective date for those institutions should be no earlier than July 21, 2015; and

• The Agencies should involve the state banking regulators as full participants in their deliberations and engage in closer consultation with Congress.

The Associations believe the proposals would have been more effective, with fewer negative consequences, if the Agencies had first conducted an empirical study of the impact of the proposals on all segments of the U.S. banking sector, bank customers and the broader U.S. economy.