The Swiss Employers' Association of Banks rejects key elements of the proposed revision of the Capital Adequacy Ordinance within the framework of the too-big-to-fail regime. 

While the association acknowledges the Federal Council's goal of enhancing systemic stability, it warns that the regulatory package goes far beyond this objective. «The Federal Council is putting the competitiveness of Swiss banks at risk, endangering jobs and potentially worsening conditions for bank clients,» the association wrote in its statement.

«Swiss Finish» in the Wrong Place

Particular criticism is directed at the complete deduction of software and deferred tax assets (DTAs) from Common Equity Tier 1 (CET1). These measures, the association argues, are neither justified by the Credit Suisse crisis nor internationally aligned. Treating investments in future technologies as «worthless» is wrong and undermines innovation. The association also firmly rejects the proposed 100 percent capital backing for foreign subsidiaries. Such a «Swiss Finish» would lead to massive overcapitalization, jeopardizing the competitiveness of affected institutions both domestically and internationally.

Call for Revision

The Employers' Association calls on the Federal Council to revise the entire package and conduct a cost-benefit analysis that also considers the impact on employment in the banking sector and the Swiss economy as a whole.

The association argues that excessive requirements could undermine, rather than strengthen, institutional stability and put numerous jobs at risk. It also highlights that banks rank among Switzerland's most attractive employers, training around 1,000 apprentices each year and upholding a longstanding social partnership that has endured for over a century.