A Crushing Capital Burden
No, we’re not talking about the proposals – enormous, complex, and in some cases ill-drafted and confusing though they are. We’re talking about how much work it’s taking to go beyond the top-line analyses and section-by-section repeats we’re seeing in so many releases to give you in-depth, strategy, and market-focused analyses of what key parts of the rules say and how they’ll redefine banking as we and the financial system know it. There’s much not to love about the current construct, but the complexity of the new capital framework makes it stunningly difficult not just for us, but we fear also for the regulators, to know if the new framework will prove a Frankenstein. When we finish our read of all the proposals’ sections and that for GSIBs, we’ll release a final, bottom-line strategic conclusion. Until then, it’s critical to understand each key part of the rule and how it defines individual business lines and the markets that depend on them.