All other banks operating in the United States will remain under the current U.S. regime, based on Basel I. The global banks’ concerns about the bifurcated U.S. application depend in part on whether they are based here or abroad.
For foreign banks the issue is the additional complexity and perceived inequity they will face if they have chosen to operate in the rest of the world under the foundation approach for credit risk, an approach which will not be permissible in the United States.