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ARTICLE · 24 SEPTEMBER 2013

Basel III Framework: US/EU Comparison

A&O Shearman
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The US and EU rules implementing Basel III follow many aspects of Basel III closely, but there are major differences in approach in several key areas.

United StatesFinance and Banking
A&O Shearman
A&O Shearman
Thomas Donegan
Thomas Donegan
Winfried Carli
Winfried Carli
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The US and EU rules implementing Basel III follow many aspects of Basel III closely, but there are major differences in approach in several key areas. Financial institutions have been engaged in a "race to the top" to show strong capital ratios but rules on leverage appear to be the most challenging and may require significant business restructuring. The interplay between the US and EU implementation of Basel III and the gradual "phase in" of certain rules, particularly on liquidity and leverage, will have a profound impact on the relative competitiveness of relevant US and EU financial institutions. This client publication, and the accompanying US/EU comparison and summary table, highlight points of international consistency and divergence.

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