The WFE have responded to the Proposed Rulemaking for Amendments to the Regulatory Capital Rule Applicable to Large Banking Organizations and to Banking Organizations with Significant Trading Activity (the “Basel III Endgame” proposal) issued by the Federal Reserve Board of Governors (FRB), Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (the “agencies”), and the Proposed Rulemaking for Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies (the “GSIB Surcharge” proposal) issued by the FRB. The response details a number of concerns regarding whether these amendments will enhance resilience in the wider financial system or incur negative knock-on-effects on central clearing. In particular, the response highlights that a significant increase to required capital will sharply reduce the viability for large banks to act as client clearing intermediaries, as the provision of client clearing is low-risk and low-return for most banks. Therefore, the WFE warn that the proposals could counteract the G20 clearing mandate and decrease the use of central clearing because of higher costs that may be passed on to end-users (who may be forced to limit their activity or leave the market) or because of reduced capacity offered by the remaining clearing members in the market.