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TCH Calls SIFI Surcharge Premature

The Clearing House Association submitted a comment letter to the banking agencies regarding the application of capital surcharges to systemically-important financial institutions in the United States. The letter argues that proposed surcharges are premature given the macroprudential reforms still being implemented and are based on untested academic models and theories. The Basel III capital reforms, when fully implemented, will result in a tripling of the amount of Tier 1 common equity currently required by the U.S. banking regulators. Moreover, the myriad systemic risk reforms contained in the Dodd-Frank Act are yet to be finalized. Given that the full impact of these reforms is not yet known, the incremental benefit of any surcharge may be minimal, particularly when compared to the potential negative macroeconomic effects. TCH’s empirical analysis demonstrates that the Basel III capital levels would have been sufficient for all banks to have survived the financial crisis. This indicates that the macroprudential benefit of a capital surcharge would likely be minimal.