The Clearing Housing Association and SIFMA submitted a comment letter to the FRB, OCC, and FDIC regarding their notice of proposed rulemaking to implement Section 171 of Dodd-Frank (the “Collins Amendment”), by replacing the transitional floors in Section 21(e) of the Advanced Risk-Based Approach with a permanent floor equal to the Tier 1 and Total risk-based capital ratios as calculated under the U.S. Basel I Standards. TCH and SIFMA expressed concern that (i) the NPR’s approach does not accommodate the possibility that the agencies’ implementation of Basel III’s risk-based standards may apply differently to core banks as compared to small banks; (ii) it is not possible to understand the operation and consequences of the Collins Amendment without simultaneously addressing the broader range of related changes in capital regulation; and (iii) the NPR does more than the Collins Amendment requires.