Public Comment AC96 Risk Based Capital Guidelines, Financial Services Roundtable, Washington, DC

1001 PENNSYLVANIA AVE., NW SUITE 500 SOUTH WASHINGTON, DC 20004 TEL 202-289-4322 Impacting Policy. Impacting People. FAX 202-628-2507 E-Mail info@fsround.org www.fsround.orgCommunications Division Ms. Jennifer J. Johnson, Secretary Public Information Room Board of Governors of the Federal Mail Stop 1-5 Reserve SystemthOffice of the Comptroller of the 20 Street and Constitution Ave., N.W.Currency Washington, DC 20551250 E Street, S.W. Docket No. R-1238 Washington, DC 20219 Docket No. 06-15 Regulation Comments Robert E. Feldman, Executive Secretary Chief Counsel’s Office Federal Deposit Insurance Corp. Office of Thrift Supervision ATT: Comments/Legal ESS th1700 G Street, N.W. Washington, DC 550 17 Street, N.W.20552 Washington, DC 20429Re: No. 2006-49 Re: RIN 3064-AC96 Re: Risk-Based Capital Guidelines; Capital Adequacy Guidelines; Capital Maintenance: Domestic Capital Modifications Dear Sir or Madam: 1The Financial Services Roundtable appreciates this opportunity to comment on the joint notice of proposed rulemaking (“NPR”) to establish an alternative risk-based capital framework for non-Basel II banking organizations (“Basel I-A”). I. Introduction In the United States, depository institutions and bank holding companies (banking organizations) are required to comply with both a leverage and risk-adjusted capital requirement. The leverage requirement is based on total on-balance-sheet assets without any adjustment for risk. ...