New risk based capital requirement have pro-cyclical effect and causes negative externalities in the economy. During recession, on one side, quality of loan portfolio deteriorates and probability of default increases resulting into increased level of provisions and write off’s and reduced capital level. This causes an increase in capital requirements which becomes more expensive. Weaker banks fail to access new capital and ultimately reduce the credit supply. On the other side, banks are required to maintain the minimum capital which results into credit supply contraction and hits the bank’s profitability leading to a situation called Credit Crunch. This situation may prolong recession. During the crisis, developing countries are more affected than developed countries and this debate is entirely new in Pakistan. This research empirically investigates the pro-cyclical effect of new capital regulation under Basel II using panel data of 47 Pakistani Banks from 2001-2012. Particularly this paper examines the capital management mechanisms using capital buffers, using Generalized Method of Moments (GMM) one step and two step estimation techniques on dynamic panel data model. The results gives evidence that capital buffer are counter-cyclical except in case of specialized banks because of difference in operations. The findings also suggest that adjustment costs, cost of raising capital and bankruptcy costs are major determines of holding capital buffer. Analysis confirms too big to fail hypothesis. Form the results, it is concluded that capital buffer are counter-cyclical, consistent with the hypothesis. The findings suggest the banks to adopt Basel III Accord.