Competitive Enterprise Institute: Coalition Letter on American Consumer Institute – Risk Transfer
* * *
Chief Counsel's Office
Attention: Comment Processing,
Attention: Comments/Legal OES (RIN 3064-AF29),
Re: "Regulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading Activity"; Docket ID OCC-2023-0008 (OCC); Docket No. R-1813, RIN 7100-AG64 (Board); and RIN 3064-AF29 (FDIC)
To Whom It May Concern:
Reducing risk for banks and taxpayer exposure while not limiting access to credit and increasing the cost of credit for bank customers, such as homebuyers, small businesses, and manufacturers, should be of paramount importance to your agencies as you work to implement the Basel III Endgame and reshape capital regulations for large banks. Unfortunately, your proposal omits Basel III Endgame reforms, such as clarifications and incentives that would allow and encourage banks you regulate to use insurance and reinsurance credit risk transfer, which would help achieve this balance.
CRTs effectively serve as a private capital buffer to protect taxpayers from the underlying credit risks. In the
Consumers, taxpayers, and banks do not need another financial crisis that results in another era of taxpayer-funded bank bailouts. They need a system of banking regulation that has both strong and effective rules and regulatory oversight, reduces risk and volatility, gives consumers access to capital and capital that is affordable, and includes checks and balances and cost efficiencies - all of which the private sector can bring to bear. Your agencies should enhance the ability of banks to secure third party analysis and distribute risk to a variety of reliable, private sector sources, including insurers and reinsurers. The agencies' capital regulations for banks should welcome and go so far as to encourage this by clarifying and calibrating capital requirements in a way that would facilitate a robust insurance and reinsurance credit risk transfer market, supporting the continued stability, efficiency, and transparency of banks.
Please make the necessary modifications to your proposal so that banks your agencies regulate and to which your final proposal would apply can use and have an incentive to use insurance and reinsurance credit risk transfer.
President/CEO
President
Director of Finance Policy
President
60
President
Frontiers for Freedom
President
Editor In Chief
(For identification only)
President
Americans for Tax Reform
Director
President
(For identification only)
Founder/Chairman
60
President
President
Chairman
Consumer Action for a Strong Economy
* * *
Original text here: https://cei.org/coalition_letters/coalition-letter-on-american-consumer-institute-risk-transfer/



Reps. Meeks, Beatty, Vargas, Horsford Lead Letter to Regulators Advocating for Small Business Credit, Affordable Mortgages
Leapstack has raised nearly 200 million RMB in Series C+ Funding, building a diversified technological value chain for health insurance
Advisor News
- Why aligning wealth and protection strategies will define 2026 planning
- Finseca and IAQFP announce merger
- More than half of recent retirees regret how they saved
- Tech group seeks additional context addressing AI risks in CSF 2.0 draft profile connecting frameworks
- How to discuss higher deductibles without losing client trust
More Advisor NewsAnnuity News
- Allianz Life Launches Fixed Index Annuity Content on Interactive Tool
- Great-West Life & Annuity Insurance Company Trademark Application for “SMART WEIGHTING” Filed: Great-West Life & Annuity Insurance Company
- Somerset Re Appoints New Chief Financial Officer and Chief Legal Officer as Firm Builds on Record-Setting Year
- Indexing the industry for IULs and annuities
- United Heritage Life Insurance Company goes live on Equisoft’s cloud-based policy administration system
More Annuity NewsHealth/Employee Benefits News
- After loss of tax credits, WA sees a drop in insurance coverage
- My Spin: The healthcare election
- COLUMN: Working to lower the cost of care for Kentucky families
- Is cost of health care top election issue?
- Indiana to bid $68 billion in Medicaid contracts this summer
More Health/Employee Benefits NewsLife Insurance News