CFA Institute Systemic Risk Council Renews “Too Big to Fail” Concerns Over Proposed Basel III Rules

Washington D.C — June 18, 2026

The CFA Institute Systemic Risk Council (SRC), an independent, nonpartisan group of financial experts and former policymakers, has issued a public comment letter warning about recent proposals by U.S. banking regulators to implement the final phase of the Basel III international capital standards.

Basel III is a global framework developed after the 2008 global financial crisis (GFC) to ensure banks hold enough capital to absorb losses and continue lending during economic stress. U.S. regulators have now released the latest set of proposals under the effort known as the Basel Endgame, aimed at modernizing and simplifying these rules while aligning them with international standards.

SRC Cochairs Simon Johnson and Erkki Liikanen noted: “The SRC acknowledges that the proposals contain constructive elements and that it is important to complete the Basel reforms.  Unfortunately, the proposals exacerbate systemic risk vulnerabilities and intentionally ignore certain Dodd-Frank Act requirements designed to prevent taxpayer funded bailouts.”

SRC Comment on Bank Capital

About CFA Institute Systemic Risk Council
CFA Institute Systemic Risk Council (Council) is a private sector, non-partisan body of former government officials and financial and legal experts committed to addressing regulatory and structural issues relating to global systemic risk, with a particular focus on the United States and Europe. It has been formed to provide a strong, independent voice for reforms that are necessary to protect the public from financial instability. The goal is to help ensure a financial system in which we can all have confidence. CFA Institute Systemic Risk Council was formed by CFA Institute and The Pew Charitable Trusts in June 2012 to monitor and encourage regulatory reform of U.S. capital markets focused on systemic risk. CFA Institute became the sole supporting organization in August 2015. The statements, documents and recommendations of the Council does not necessarily represent the views of the supporting organization.