In July 2023, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation proposed capital rules known as the US Basel III ‘endgame’ based on the global minimum regulatory capital standards developed by the Basel Committee on Banking Supervision (BCBS). If finalized as currently drafted, the US Basel III proposal will have a significant negative impact on trading activity and the liquidity and vibrancy of the US capital markets, with adverse effects on derivatives end users, investors, businesses and consumers.
In response to the proposal, ISDA and the Securities Industry and Financial Markets Association (SIFMA) conducted a quantitative impact study (QIS) that showed that the market risk portion of the proposal, known as the Fundamental Review of the Trading Book, will result in a substantial increase in market risk capital of between 73% and 101%, depending on the extent to which banks use internal models. This matters because trading and capital markets activities play a crucial role in the ability of US businesses to raise funds and perform risk management functions, with debt capital markets in the US representing 75% of total financing. By requiring banks to hold additional capital that is misaligned with levels of risk, the proposal would significantly reduce capital market access for US end users and businesses, restrict the ability of businesses to hedge exposures to changes in commodity prices, and increase the cost of everyday consumer goods, including food and gasoline.
Based in Basel, Switzerland, the BCBS develops global minimum regulatory capital and liquidity standards through a multi-year process involving regulators from participating countries around the world. Given the BCBS has no enforcing powers, each jurisdiction transposes those standards into local law or regulation, as applicable. Although jurisdictions participating in the Basel process generally follow these standards, they may deviate to reflect philosophical differences and national priorities on local markets and economies. However, the US Basel III proposal would impose more stringent requirements than those embodied in the global framework in several areas.
This note summarizes key findings based on the results of the ISDA/SIFMA QIS.
Click on the attached PDF to read the full paper.
Documents (1) for US Basel III Endgame: Trading and Capital Markets Impact
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ISDA AGM Studio: David Bailey
David Bailey, executive director, prudential policy, at the Bank of England, speaks with ISDA CEO Scott O’Malia about the UK’s approach to Basel 3.1, the impact of the revised US Basel III endgame on cross‑border consistency and the role of the...
ISDA AGM Studio: Harleen Bains and Sonali Das Theisen
How have trading desks responding to increased market volatility this year? Harleen Bains, ISDA board member and head of global markets sales, Canada, at RBC Capital Markets, and Sonali Das Theisen, global head of FICC e‑trading and markets strategic investments...
ISDA AGM Studio: Scott O'Malia and Chris Edmonds
Christopher Edmonds, president, fixed income & data services, at Intercontinental Exchange, speaks with Scott O’Malia, ISDA CEO, about how market volatility, regulatory change and technological transformation are reshaping global markets. The discussion explores what recent volatility has meant for participation,...
ISDA AGM Studio: Bill Borden, Microsoft
Bill Borden, corporate vice president, worldwide financial services, at Microsoft, speaks with Mark New, ISDA’s co-head of digital transformation and senior counsel, about how artificial intelligence (AI) is shaping the future of financial markets and the key factors firms should...
