There is a growing wave of opposition to Basel III Endgame, and former U.S. financial officials are criticizing the proposal.

• Former OCC Chief Counsel and First Senior Deputy Comptroller Julie Williams commented on regulators' misplaced focus on capital regulation: "How do I say this? There are lots of people that have invested a lot of time in becoming experts in the minutia of capital regulation. And they just sort of keep going."
• Former U.S. Secretary of the Treasury Larry Summers urged regulators to focus on commercial real estate rather than capital requirements: "It would be much more productive for our central bank to be focused on the question of real estate portfolios in the banks they supervise [than] some of the more abstract and politically driven arguments about various kinds of capital charges on the largest banks."
• Former Federal Reserve Governor Randall Kroszner explained that regulators have not provided an adequate analysis of the impacts or a thorough justification of the costs: "Capital is a blunt regulatory instrument that has the potential for unintended consequences. The agencies provided only a very broad qualitative assessment of the proposal's costs and benefits and did not provide thorough analyses supporting their conclusions that the benefits of the proposal outweigh its costs."
• Former President and Chief Executive Officer of the Federal Reserve Bank of New York Bill Dudley explained that more capital is not a universal solution: "Regulators were right to impose much higher capital requirements after 2008. Yet there's a point of diminishing returns. Capital is crucial, but more capital isn't the right solution for every problem."

Regulators need to listen to their peers and really consider the consequences of Basel III Endgame as written. It's time to scrap this proposal and start over.