BPI Submits Supplemental Comments on Basel III Endgame Proposal

Ladies and Gentlemen:

On behalf of the Bank Policy Institute[1] please find attached as Annex 1 hereto a supplement to our comment letter filed January 16, 2024 in response to the above referenced proposal. Annex 1 provides supplemental research on the proposed 10 percent credit conversion factor that would be applied to the unused portion of consumer credit card lines.

To read the full comment letter, please click here, or click on the download button below.

[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.