The proposed new capital regime, developed in less than open deliberations by the global experts at the Basel Committee, remains relatively unexposed in its foundations and methodology to public light by the [Fed] Board, even while the Board proposes to apply substantially heavier requirements on U.S. banks than are being applied internationally. [I]t is important that new capital regimes, particularly those developed outside of the United States, be given the fullest public exposure to ensure consistency with recent reforms and the needs of the U.S. economy.
As proposed, the surcharge would currently apply to the eight U.S. G-SIBs as designated by the Basel, Switzerland-based Financial Stability Board. However, the rule would require U.S. banks with more than $50 billion in assets to calculate a measure of their potential significance. The proposal also includes methods of calculating the surcharges that would result in capital surcharges ranging from 1% to 4.5% of total risk-weighted assets.
Read the letter.