On January 16, 2024, the comment period closed for the US banking regulators’ Basel III Endgame proposal. Nearly 200 comment letters were submitted from the financial sector, commercial user, and the general public.

Mayer Brown has been actively engaged on this important rulemaking. We have helped clients draft numerous comment letters, including for the Structured Finance Association, the CRE Finance Council, the National Association of Manufacturers, the London Stock Exchange Group, the Federal Home Loan Banks,  and several commercial end-users.

Soon after the proposal was issued, Mayer Brown attorneys, Chris Horn, Stuart Litwin, and Matt Bisanz, wrote a white paper on its impact on securitization that was a cited in a letter from the House of Representatives urging regulators to consider the consequences of the proposal on securitization and capital markets activity.

Mayer Brown partner Andrew Olmem testified before Congress on the administrative law and policy issues raised by the proposal.

The firm also hosted a conference on the proposal, which included a major address by FDIC Director Jonathan McKernan, as well as discussion panels that included Mayer Brown attorneys Angel Ulum, Anna Pinedo, Andrew Olmem, and Matt Bisanz.

The US banking regulators will now review the submitted comments. It also is likely that another round of comments will be solicited on the information that banks have submitted regarding the proposal’s likely effect. We expect the debate and process for the proposal will continue throughout most of this year.

To review all of Mayer Brown’s work on the proposal, please visit our Basel Resource Center.