On September 10 the IIF Steering Committee on Regulatory Capital submitted its response to the Basel Committee's consultative document Countercyclical capital buffer proposal. The consultative document lays out the primary objectives and function of the countercyclical buffer as well as key elements of its proposal. The Institute has, in a number of publications beginning in 2008, embraced the premise that taking measures to reduce procyclicality is sound in principle; however, the response raises risk-management and practical implementation questions arising from the proposal and elements of the macroeconomic methodology that is the basis of the proposal, such as the credit:GDP measure. In the response, the IIF offers structural critiques of the capital tool and urges caution regarding the implementation of such an untested mechanism.