The undersigned organizations are concerned about the proposed rule known as the “Basel III Endgame” that would substantially increase capital requirements on covered U.S. banks and make capital and credit more expensive for businesses of all shapes and sizes. The proposed capital increase is without merit given the U.S. banking system is more than adequately capitalized and continues to demonstrate its resilience. Banking regulators should not advance a capital increase that hamstrings U.S. businesses and make an already challenging economic environment worse for working Americans.

The federal banking regulators have not justified why a significant increase of capital on U.S. banks is necessary or appropriate. In fact, large banks passed their annual stress test in June, with the Federal Reserve Board concluding these banks are, “well positioned to weather a severe recession and continue to lend to households and businesses even during a severe recession.”A survey of 300 corporate treasurers and financial decision-makers found that businesses are not overly concerned about the stability of individual banks or the banking system, ranking this issue as number 8 out of 10 potential concerns.