“[Global systemically important banks] should be on the lookout for stricter standards for how they calculate capital under the advanced internal ratings-based approach. The Basel Committee for Bank Supervision is likely to reduce the flexibility that large banks have in calculating risk weighted-assets. This will impose additional data and compliance burdens on banks. The Basel committee will also continue to demand transparency from banks into their inputs and models for how they calculate RWAs. In the U.S., I expect that the Volcker Rule compliance date will be extended for large banks and certainly for smaller banks. Expect a full year of large banks trying to weaken the Volcker Rule. Given how poorly they are doing at implementing it, this should be no surprise.”