Institute of International Bankers

Summary: The Institute of International Bankers (IIB) supports the goal of improving the U.S. capital framework but proposes specific modifications to the Standardized Approach and ERBA proposals. They argue for indexing thresholds to nominal GDP, retaining the existing definition of "commitment," allowing faster AOCI recognition, and providing preferential risk weights for certain corporate and bank exposures to maintain international competitiveness.