The banking agencies should use an advance notice of proposed rulemaking process to formally solicit public and congressional input prior to engaging in international standard-setting discussions, ABA said in a letter to regulators Monday. They also should conduct empirical studies of how a proposed international standard would impact the U.S. banking system, bank customers and the economy.
“The ANPR process, as well as the related study, would enhance the likelihood that the Agencies were fully informed as they negotiated with the Basel Committee and/or the Financial Stability Board,” ABA wrote.
In the same letter, ABA urged the agencies not to adopt the Basel Committee’s proposed Revised Standardized Approach as a second risk-based capital floor for banking organizations globally, noting that it would create costly and redundant systems with no additional safety and soundness benefit to U.S. banks. Read the letter. For more information, contact ABA’s Hugh Carney.