CFA Institute Systemic Risk Council (the Council) recently provided detailed comments on the Basel III proposals from the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation.  The Council provides analysis of the so-called endgame to ensure proper framing of capital adequacy, the relationship between capital and lending and why capital improvements since the Global Financial Crisis continue to fall short.  The Council offers its support to the agencies’ efforts to implement the Basel III international standards for large banks because; (i) they are an important step in ensuring that large banking organizations are appropriately capitalized, (ii) they improve GFC era reforms and reduce the probability of global financial contagion, (iii) they bolster the ability of our system to withstand severe economic downturns without the need to resort to the use of taxpayer dollars or extraordinary support measures.

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