Securities Industry and Financial Markets Association Asset Management Group

Summary: The Securities Industry and Financial Markets Association Asset Management Group (SIFMA AMG) opposes several components of the proposed Basel III capital standards. They argue that the proposal's CVA and FRTB DRC requirements, the treatment of ETFs as systemically risky, and the lack of consistent risk-sensitive treatment for investment-grade corporate exposures will increase costs, reduce liquidity, and harm retail and institutional investors.