Basel III Endgame is bad banking policy

Yesterday, Senator Elizabeth Warren (D-MA) sent a letter to Federal Reserve Chair Powell urging him to advance the proposed Basel III Endgame banking rule.

Over 97% of the comments on the proposal were negative, and 86% came from individuals outside of the banking sector. Sen. Warren's letter overlooks the people across America, including farmers, manufacturers, small business owners, and community advocacy groups, who have all raised a wide range of concerns about the proposal:

  • The NAACP and other advocacy groups: "If these standards are adopted, they will have a devastating impact on our efforts to increase Black homeownership and disadvantage all first-time, and, in particular, first-generation homebuyers who do not have the benefit of multi-generational wealth or higher than average incomes."
  • Representatives Horsford (D-NV), Beatty (D-OH), Meeks (D-NY), Vargas (D-CA), and over 50 Democrats: "Businesses and consumers, including first-time homebuyers, are experiencing continued cost pressures and barriers to financing options. We have specific reservations about the proposal’s potential impact on mortgage affordability that could exacerbate the racial homeownership gap and business credit availability, which is a vital pathway to wealth creation for minority communities."
  • Senators Peters (D-MI), Stabenow (D-MI), Carper (D-DE), Hickenlooper (D-CO), and Rosen (D-NV): "Increasing capital requirements for banks pose undue consequences that can lead to further borrowing costs or limit the access to capital for small businesses, households, and consumers that rely on lending services."
  • Representative Chris Pappas (D-NH): "[Basel III Endgame] is a very significant and complex regulatory proposal. There are a lot of concerns. I hear them from my Main Street business sector, my lending community, that it could have potential downstream impacts in terms of access to capital."
  • Everett Sands, Founder & CEO, Lendistry: "We should recognize that we are in an inflationary environment. We should recognize that the rule is a proposal but it is not ready for the current environment that we're in today. So my actual recommendation would be to postpone Basel III as it stands today, because as others have indicated, it will start at the top banks. It will then trickle down into community banks. It will then trickle down into community development financial institutions, and afterwards, it then obviously go to small businesses."
  • The National Housing Conference: "Raising capital standards discourages lending and reduces credit availability through downstream impacts, which will likely be felt first and foremost by lower income businesses and underserved groups who are often overrepresented as borrowers with riskier loans. This means that an LMI small business owner who previously could have been funded through CRA-driven investment may not see that investment because community development initiatives under CRA will be stressed or negated."
  • The American Public Power Association and National Rural Electric Cooperative Association: "If the Proposed Rule is adopted as drafted, we fear that there will be a decrease in hedging, increased costs to our consumer members, and increased market volatility in the energy sector, which is already facing many uncontrolled externalities."
  • The National Association of Manufacturers: "Subjecting U.S. banks to much higher capital requirements than their international peers would put U.S. manufacturers at a competitive disadvantage in the global marketplace."
  • Agriculture advocacy groups, including American Farm Bureau Federation and the National Council Of Farmer Cooperatives: "We are concerned that recent bank capital proposals will have unintended consequences for the health of US derivatives markets and make hedging significantly more expensive for all market participants."
  • Federal Reserve Governor Michelle Bowman: "We still don't fully understand all of the different aspects of this 1,100 page, very complex rule that we really need to have a better understanding of…in my mind, I think it would be helpful for us to have an economic analysis of whatever the final proposal might be, in addition to our quantitative impact study for the institutions themselves."

It's time for regulators to scrap the proposal and start over.