The complexity of many of the new risk-weighted assets rules, particularly for community banks. In particular, the new residential mortgage risk-weighting requirements require much more complex and granular risk treatment under the proposed rules, and when combined with other Dodd-Frank Act rulemaking affecting mortgage lending, could significantly impair community banks' ability to conduct a viable and robust residential lending business. Other concerns related to the real estate lending rules include:

The inclusion of unrealized losses and gains on available-for-sale debt securities in regulatory capital. This could result in large and volatile changes in a bank's capital level, especially when interest rates begin to rise from their current historical lows. Commenters argued that these changes subject bank regulatory capital requirements (and other regulatory requirements, such as lending limits, that are tied to regulatory capital) to too much exposure to changes in interest rates (instead of specific credit risk), and overstate the real impact of such changes on the bank's safety and soundness. Community bankers also argue they are disadvantaged by these rules because they have fewer options for managing the resulting capital volatility in comparison with larger banks.

Subjecting thrift holding companies that have significant insurance activities to the Basel III rules. These institutions argue that the requirements are not suitable for the insurance business model and do not account for the longer-term nature of their liabilities and their practice of matching asset and liability maturities.