Today, in response to a question on how regulators were working to minimize the impact on consumers from the Basel III Endgame, Federal Reserve Vice Chair Michael Barr said the Fed and other regulators "...want to make sure there aren't any unintended consequences… So the public comment that we're getting on this is really critical for us getting it right, and we take it very, very seriously."

The voices warning about unintended consequences from the rule continue to grow. Following are just a few of the many organizations that have voiced to the Federal Reserve the negative impact Americans will see from the proposed rule: 

• Pension groups on how it will hurt pensioners and retirees: "There are unintended consequences in the Proposal... The Proposal would punish CalPERS – and its two million beneficiaries – because it does not issue publicly traded debt securities. That error should be remedied." (California Public Employees' Retirement System, 2023)
• Agricultural trade groups on how it will hurt farmers: "We are very concerned that any contraction in the availability of clearing services will have a disproportionate impact on agricultural end-users that are far outside the major financial centers, especially smaller entities such as grain elevators and family farms. We urge you to modify the proposals so that they do not disincentivize banks from providing this important service to their customers." (Commodity Markets Council, National Council of Farmer Cooperatives, National Cattlemen's Beef Association, et al., 2023)
• Climate advocacy groups on how it will hurt investments in clean energy: "Substantially higher capital costs for banks could significantly increase the costs of clean energy projects and result in far fewer projects being built. Furthermore, carbon reduction goals may not be met, jobs could be lost, manufacturing could be stunted, and equitable access to clean, low-cost energy could be reduced—all of which are inconsistent with the administration's climate initiatives and the IRA." (American Council on Renewable Energy, 2023)

As illustrated by the variety of comments above, the Federal Reserve needs to go back to the drawing board on Basel III Endgame. It's time for Vice Chair Barr and the Fed to listen.