Regulatory Capital: Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations

The Appraisal Institute supports the proposed regulatory capital rule, specifically praising its continued reliance on independent real estate valuations to determine loan-to-value ratios and assess collateral risk. They argue that independent appraisals are essential for objective risk management, preventing conflicts of interest, and ensuring the safety and soundness of the banking system.

Public Citizen opposes the proposed rules, arguing that they reduce solvency standards by approximately 6 percent and increase systemic risk by allowing large banks to "model-game" their risk weights. The organization contends that these reductions undermine financial stability, favor executive compensation over safety, and fail to address the liquidity vulnerabilities exposed by recent regional bank failures.

United States Senators Elizabeth Warren, Jack Reed, Chris Van Hollen, Richard Durbin, and Richard Blumenthal are requesting that the banking agencies withdraw the proposed capital rules. They argue that the proposals (including the "Basel III Endgame") would reduce loss-absorbing capital requirements for large banks, increase systemic risk, and potentially violate the Dodd-Frank Act.

Anita H opposes the proposed reduction in capital requirements for banking institutions, arguing that it compromises the safety of consumer deposits. She contends that the rule favors wealthy elites and "banksters" at the expense of everyday citizens and the nation's economic stability.

The commenter, a private resident of Georgia, is requesting a 180-day extension of the public comment period for the proposed rule. They argue that the current timeframe is insufficient for the public to properly evaluate the complex and lengthy proposal.

Anita H., a resident of Georgia, opposes the proposed reduction in capital requirements for banking institutions. She argues that lowering these buffers increases systemic risk, threatens depositor protection, and could lead to more frequent bank failures and economic instability.

A group of academics from various universities (including NYU Stern, Harvard, and Columbia) argues that the proposed rule would weaken the U.S. banking system's resilience by materially lowering capital requirements for systemically important banks. They contend that the agencies lack sufficient evidence to justify these cuts, misapply the nonbank migration rationale, and create dangerous deviations from international Basel III standards.

Senators Elizabeth Warren, Jack Reed, Chris Van Hollen, and Tina Smith are requesting a 180-day extension of the comment period for the proposed capital rules. They argue that the proposals are overly complex, would reduce loss-absorbing capital at big banks, and could increase the risk of bank failures and taxpayer bailouts.

Jason Smith, a concerned depositor, opposes the proposed modernization of the regulatory capital framework because he believes the reduction in required capital buffers will increase risks to banking stability and depositor protection. He argues that the proposal prioritizes lending growth over financial resilience and urges the agencies to maintain more conservative capital requirements to prevent future bank failures.

An individual commenter opposes the proposed rule, arguing that it allows for too much risk and insufficient protection for bank deposits. They advocate for banks to be required to hold more reserves to safeguard the money of depositors.