The Federal Reserve is looking hard at increasing the amount of capital that banks must hold in the Fed’s effort to boost bank liquidity, or their ability to handle sharply increased withdrawal rates.

There is pushback against this proposal, including objections that it might make it harder for banks to lend to folks on the lower economic tiers, even that it might make American banks less competitive than foreign competitors. That last often (not always) is just political Newspeak for “be more like Europe.”

However, the problem can be preempted—or at least pushed a considerable way down the road, allowing for more thought—by doing something different that IMNSHO is a better move, anyway.

Rather than increasing capital requirements, require all banks to mark to market (semiannually? quarterly?) all of the debt instruments the banks hold in satisfaction of existing capital requirements.

Then leave that requirement in place for some period of time (5 years, say) in order to get a serious look at how well, or poorly, that requirement supports bank liquidity during economic downturns.