Great Pacific Bank has the following balance sheet (in millions), with the risk weights in parentheses. There are no off balance sheet activities for this bank.

Assets		Liabilities and Equity
Cash (0%)	$15	Deposits	$280
OECD interbank deposits (20%)	15	Subordinated debts (10 years)	5
Mortgage loans (50%)	170	Non cumulative (perpetual) preference shares	5
Consumer loans (100%)	100	Equity	10
Total Assets	$300	Total liabilities and equity	$300

a) Assuming operational risk and market risk are equal to zero, does the bank have enough capital to meet the Basel III Common Equity Tier 1, Total Tier 1, Total capital requirements?

b) Explain the reasons why some off-balance sheet instruments are excluded in the calculation of credit risk adjusted off-balance sheet asset value.

c) Explain how capital buffers imposed in Basel III attempt to address counter cyclical and systemic risk issues of Basel II.

d) Explain why Basel III capital requirements are still unable to create a level competitive playing field across all banks on a global level.