Stakeholders from across industries have been speaking out about the negative consequences of Basel III Endgame, including pensioners and retirees. 

Under Basel III Endgame, Americans saving for retirement will see increased costs and reduced returns. 

• The State of Wisconsin Investment Board and the Ohio Public Employees Retirement System stated that the proposal will interfere with access to financial services that are critical to providing retirement security for millions of Americans: "As currently written, the Proposal would interfere with our ability to access critical services, manage our assets in ways that create value for our members, and allow us to prudently manage our risk. The cumulative effect of these impacts is that U.S. public pension funds will experience increased costs, as well as additional volatility and risk, despite the fact that our Systems are highly creditworthy, transparent, accountable entities that provide retirement security for millions of Americans." (State of Wisconsin Investment Board and Ohio Public Employees Retirement System representatives Edwin Denson and Paul Greff, Letter, 1/16/2024)
• The American Benefits Council cautioned that the proposal would negatively impact pension plans and investors: "We have deep concerns about the effects of the proposal on pension plans and the participants they serve...the proposal would significantly increase banks' capital requirements for derivatives and SFTs (securities financing transactions), among other transactions. These costs would be passed on to end users (such as plans), increasing the cost and reducing the availability of these products. The loss of these products at a reasonable price—or the unavailability of these products—will result in some plans managing risks in less effective ways, which will undoubtedly lead to higher costs (again at the expense of participants and beneficiaries) and more harmful volatility. The specter of higher costs and increased volatility will in turn result in more employers terminating their plans, again hurting participants." (American Benefits Council, Letter, 1/12/2024)
• California Public Employees' Retirement System (CalPERS) argued that Basel III Endgame would hurt retirees: "There are unintended consequences in the Proposal, which would impose a uniform credit valuation adjustment on public sector entities that is not representative of those entities' risk or creditworthiness… 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, Letter, 12/22/2023)

Retirees and pensioners can't afford Basel III Endgame. It's time for regulators to scrap the proposal and start over.