American Express Company
American ExpressSupportBusiness
Summary: American Express supports the proposed Basel III implementation as a substantial improvement over the 2023 proposal, noting it better aligns capital to risk. However, the company argues that the proposals are still miscalibrated for its specific business model and requests several targeted refinements to credit risk, operational risk, and market risk frameworks.
Attached, please find comments from American Express on the interagency proposals (i) to revise the capital requirements applicable to large banking organizations and to banking organizations with significant trading activity and (ii) to make certain related or conforming revisions to the current standardized risk-based capital framework. Thank you in advance for your time and consideration