On July 27, 2023, the US banking regulators issued a proposal to significantly revise the risk-based capital requirements applicable to large banks and to banks with significant trading activity. The proposal, which is colloquially referred to as “Basel III Endgame” or “Basel IV,” includes important changes to the calculation of credit risk weights for securitization

Earlier this year, the SEC re-proposed a rule to implement Section 27B of the Securities Act of 1933, a provision added by Section 621 of the Dodd-Frank Act.

The Dodd-Frank provision, intended to prohibit certain conflicts of interest in securitization transactions, is interpreted broadly by the SEC’s sweeping proposal. If not amended, these rules would