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