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NURFS is broadly supportive of the proposed Basel III capital rules but has concerns with certain aspects that raise concerns for Owner Banks.

NURFS opposes the D-SIB capital surcharge, but urges the Basel Committee to make any such surcharge transparent and subject and national discretion.

NURFS believes the existing AOCI filter should remain in place, at the very least for certain high-quality liquid assets.

NURFS submitted a follow-up comment letter to the FRB, responding to questions raised at our September 20 meeting with respect to deferred tax asset calculations for regulatory-capital purposes under Basel III.

NURFS explains why the banking agencies should not eliminate the existing filter of certain unrealized gains and losses on financial instruments.