AFR commented on a set of banking agency proposals for implementing the initial Basel III rules for U.S. banks. These rules cover the definition of capital, base levels of capital for all banks, risk weighting, and exposure measurement. Upcoming rules will address capital charges for larger banks and liquidity reserves. The AFR comment called for significantly higher leverage limits for banks and a simpler (and less manipulable) set of rules for risk weighting and exposure measurement.

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