Davis Polk partner Luigi De Ghenghi advised a group of large regional banks on a comment letter in response to the Federal Reserve Board, OCC and FDIC regarding their jointly proposed revisions to the Basel III capital rules. The proposal would significantly increase capital requirements for Category I – IV banking organizations over a three-year transition period. The proposed rule is broadly intended to bring the U.S. capital rules into conformance with the current version of the Basel Committee on Banking Supervision’s (BCBS) international capital standards (the Basel Framework).

The letter highlights that the proposed rule suffers from a number of deficiencies, including stricter requirements that would make it more expensive for these U.S. banking organizations to engage in fundamentally important mortgage lending, small business lending and consumer financing activities.

Read the letter here