Indeed, some commenters indicated that a change to an even simpler system would in itself be more burdensome than sticking with the current regime. The notice also asked whether the industry would be in favor of a blunt, stand-alone leverage ratio with much less complexity and reporting.
The catch to that proposal was that in exchange for less risk reporting, supervisors would set the minimum ratio higher than is required by the current leverage standard, which is used in tandem with the current risk-based system. Many of the responses indicated that was not a favorable tradeoff, even though most community banks have exceptionally strong leverage ratios.