Outline of Key Issues for NYCH comment letter on the proposed new Basel Capital Accord

May 31, 2001Basel Committee on Banking Supervision,Bank for International Settlements,CH-4002, Basel, Switzerland.Re: The Proposed New Basel Capital AccordLadies and Gentlemen:The member banks of The New York Clearing House1Association L.L.C. (the "Clearing House") appreciate theopportunity to comment on the consultative paper by theBasel Committee on Banking Supervision (the "Committee")concerning The New Basel Capital Accord (the "Proposal").The Clearing House has eagerly awaited theCommittee’s proposed new regulatory capital framework,anticipating that it would reflect industry assessments ofeconomic capital by incorporating more risk sensitivecapital charges. We believe, however, that the Proposaldoes not achieve this objective in a number of key respects.The Clearing House acknowledges that the Proposal makespositive advances in a number of areas, but we believe that— without substantial revision — implementation of theProposal could have potentially significant negative1The member banks of the Clearing House are: Bank ofAmerica, N.A.; The Bank of New York; Bank One, N.A.;Bankers Trust Company; The Chase Manhattan Bank;Citibank, N.A.; European American Bank; First UnionNational Bank; Fleet National Bank; HSBC Bank USA;Morgan Guaranty Trust Company of New York; and WellsFargo Bank, N.A.NY12532:298925.8Basel Committee on Banking Supervision -2-consequences for the financial services industry and theeconomy.At the outset, the Clearing ...