Basel III Endgame, the controversial banking proposal, has been criticized by a broad-based group of stakeholders. The proposed capital requirement increases would raise the cost and decrease the availability of consumer lending products, making auto loans less accessible for millions of Americans.

• The U.S. Chamber of Commerce noted that the proposal will push consumers away from bank-provided auto loans, decreasing competitiveness and destabilizing the auto industry: "The Proposal would likely continue the migration of consumer auto loan products from banks to other lenders (e.g., credit unions and finance company subsidiaries of auto manufacturers) due to the banks' competitive disadvantage from higher costs. This would lead to decreased competition and potentially higher prices for consumers. This change also may lead to adverse effects on auto dealers and generally disrupt the auto and auto finance markets, which, like other consumer markets, currently are under incredible stress." (U.S. Chamber of Commerce, "'Endgame' for Main Street Lending," 1/17/2024) 
• Santander Holdings argued that the proposal's risk weighting measures will be particularly harmful for auto lending: "We believe, accordingly, that treating all loans for which there has been a credit-related term extension as 'defaulted exposures' and applying 150% risk weight to those credits would result in punitive treatment for borrower-friendly measures and lead to a reduction in attempts to help borrowers by offering such extensions. This could have an especially large and disproportionate impact on auto lending, where access to transportation is often a critical priority for borrowers." (Tim Wennes, President and CEO of Santander U.S., Letter, 1/16/2024)
• The Financial Services Forum outlined how the proposal will decrease U.S. banks' consumer offerings, making it harder for Americans to make large purchases like buying a car: "The breadth of this Proposal would materially increase the cost of all financial services provided by our member institutions. Among other things, the Proposal would decrease the availability and increase the cost of: (1) lending to households to finance an array of important purchases such as a home or automobile" (Financial Services Forum, Comment submitted to FDIC/Fed/OCC on Basel III endgame proposal, 1/16/24) 

There is no doubt about it: regulators need to scrap Basel III Endgame and start over.