One of the criticisms of Basel 2 is that it is procyclical. That means that

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Basel 2 is considered procyclical because it requires banks to hold more capital during times of economic expansion when the availability of credit is high and less capital during economic downturns when credit is less available. This can create a "boom-bust" cycle in the economy, as banks may be forced to reduce lending during economic downturns to meet capital requirements, exacerbating the economic slowdown.

One of the Criticisms of Basel 2 Is That It