The Basel Committee on Banking Supervision will put "concrete recommendations" for completing Basel III to central bankers and supervisors when they meet later this month.Basel III is the committee's proposals for tougher global capital and liquidity rules. The recommendations take account of responses to the reform package, which it put out to consultation in December 2009. The recommendations also take account of the results of a quantitative impact study and macro-economic impact assessment analyses.Patricia Jackson, head of Ernst & Young's EMEA prudential advisory practice, said that a number of detailed but important elements of the proposals were causing widespread industry concern. These included the stable funding ratio, the charge for credit value adjustment risk, the treatment of deferred tax assets, and the potential for double counting in the treatment of minority interests (something that affects all banks that have grown by acquisition). All these, Jackson said,  would need to be addressed by the time the whole package was presented to global political leaders at the Seoul G20 meeting in November. Jackson said: "These most difficult elements are likely to be ironed out, but the question is how far they are going to be ironed out by September, when there are key meetings in advance of the Seoul G20 summit. They haven't got much time."Another issue, said Jackson, was that the new requirements would be coming in just as central banks and governments began withdrawing their support of those banks that had got into trouble during the crisis. "The issue is how you calibrate the whole Basel III package, given the number of components, how long you give people to implement it, and how you work out what the costs will really be, during a transition period when the industry is not in equilibrium," she said.As a member of the Basel Committee, Jackson headed the quantitative impact study on Basel II. She said Basel III represented a much more radical change than the shift from the original Basel Accord to Basel II. "Basel II was difficult to implement, but it didn't have so many moving parts, and it didn't have such a potential to create distortions," she said.In advance of publishing the whole package, the committee last week issued a consultation document on one of its key elements, a proposal for countercyclical capital buffers. These "add-on" buffers would be in addition to the "capital conservation buffers" also included in the package, and they would be imposed when national regulators judged that excessive credit growth was leading to system-wide risk. In its consultation document the committee made clear that the primary aim of the buffers was to protect banks rather than "leaning against the wind" of asset price growth. It did add that any moderating effect the buffers would have on the build-up phase of the credit cycle would be "a positive side benefit".Richard Barfield, a director at PricewaterhouseCoopers LLP, said that a general concern with the proposed reforms was their attachment to the blunt instruments of capital and liquidity buffers at