The U.S. Chamber of Commerce (“Chamber”) Center for Capital Markets Competitiveness submits these comments in response to the Board of Governors of the Federal Reserve System’s (“FRB”), the Federal Deposit Insurance Corporation’s, and the Office of the Comptroller of the Currency’s (“Agencies”) joint proposed rulemaking entitled Regulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading Activity (“Proposal”).
As U.S. capital standards are traditionally stricter than international counterparts, the Chamber believes that the Proposal’s implementation of the Basel Committee on Banking Supervision (“BCBS”) recommendations lacks a rationale for a problem it seeks to solve. Failure by the agencies to adhere to procedures in the Administrative Procedure Act (“APA”) make the proposal arbitrary and fails to provide a basis for moving forward. Furthermore, the Chamber has serious concerns with the Proposal and its impacts upon banks, consumers, businesses, and the broader U.S. economy.