In its consultation response, the Swiss Bankers Association (SBA) rejects the Federal Council’s proposal to amend the Banking Act and the Capital Adequacy Ordinance with regard to the capital backing of systemically important banks’ foreign participations at parent company level. Instead, the SBA calls for proportionate, targeted regulation that is aligned with international standards. It also demands a thorough review of viable alternatives to the proposed maximalist approach as well as a holistic view of all planned measures to avoid unnecessary burdens on the financial centre and the real economy. The goal must be to strengthen system stability while also securing Switzerland’s competitiveness as a location for finance and business.