Bank Policy Institute, American Bankers Association, U.S. Chamber of Commerce, and Consumer Bankers Association

Summary: The Bank Policy Institute, the American Bankers Association, the U.S. Chamber of Commerce, and the Consumer Bankers Association support the agencies' tailored approach to capital requirements and the goal of improving risk sensitivity. However, they strongly oppose specific proposed revisions to the definitions of "commitment" and "unconditionally cancelable," arguing these changes are ambiguous, lack a clear legal anchor, and would create unquantifiable increases in capital requirements.