As previously covered by InfoBytes, the federal banking agencies issued a notice of proposed rulemaking that would substantially revise the capital requirements of large U.S. banking organizations. According to the letter, Congress has very little insight into the basis of such policy changes that “would fundamentally change the policy of the U.S. banking system.”

The letter requests the GAO to evaluate each federal banking agency’s participation in the development of Basel III Endgame. GAO’s evaluation should include: (i) a summary of each material proposal submitted by a federal banking agency to the Basel Committee; and (ii) a summary of concerns raised by a federal banking agency with respect to a consultative document or other proposal considered by the Basel Committee.

Further, the letter requests the GAO prioritize each proposal or concern from the federal banking agencies related to:

• Any proposals or concerns from the federal banking agencies that did not receive a fulsome response by the Basel Committee.
• Any evidence or rationale supporting the requirement that a “corporate entity (or parent) must have securities outstanding on a recognized securities exchange for an exposure to that entity (or parent) to be eligible for the reduced risk weight for investment-grade corporate exposures;”
• The absence of a tailored approach to “high-fee revenue banks under the Basel III Endgame business-indicator approach to operational risk capital”;
• The calibration of the “scaling factor, multiplier, dampener, and other coefficients for that business-indicator approach”; and
• The calibration of the “correlation factors and the profit-and-loss attribution test thresholds for the models-based measure of market risk capital.”