In a letter to the European Commission, FIA Europe welcomes the opportunity to provide feedback on the Public Hearing on the Liquidity Coverage Requirement and the Leverage Ratio that the European Commission organised on 10 March 2014.On 17 March 2014 a number of trade associations sent a letter to the Basel Committee on their revised Basel III Leverage Ratio framework and disclosure requirements that they had published in January 2014 (BCBS270 document). Having reviewed the EBA’s Report on impact of differences in leverage ratio definitions and following the public hearing, FIA Europe took this opportunity to reinforce some of the points raised in the attached letter sent to the Basel Committee and to highlight some of the areas of uncertainty of interpretation that remain outstanding, with a view to providing guidance of areas that would benefit from clarification in the European Commission’s draft Delegated Act that is to be published pursuant to CRR Article 456(1)(j).The key recommendations can be found in the full letter and attachments.
CONTINUE READINGThe Associations support the Committee’s efforts to impose a leverage ratio as a supplementary backstop measure to the risk-based measure and we appreciate this opportunity to provide feedback on the final leverage ratio framework in the form of frequently asked questions (FAQs).
CONTINUE READINGWe recognize that the BCBS framework is intended to create a common standard for all global banking organizations, and accordingly, where there are gray areas regarding how the finalized language should be interpreted, technical guidance should be issued to ensure consistent international implementation.
CONTINUE READINGBanking regulators are putting in place a new set of international capital standards aimed at strengthening the banking system’s capital base. One consequence is that the cost of providing clearing services will rise dramatically over the next several years.
CONTINUE READINGFIA has published guidance regarding the standards that need to be satisfied in order for a clearing member to conclude that the margin it posts to a clearinghouse is "bankruptcy remote" for purposes of the Basel III capital requirements.
CONTINUE READINGFIA has published guidance regarding the standards that need to be satisfied in order for a clearing member to conclude that the margin it posts to a clearinghouse is "bankruptcy remote" for purposes of the Basel III capital requirements.
CONTINUE READINGFOA Letter to Basel regarding New Liquidity Requirement to Client Cleared Derivatives
CONTINUE READINGFIA submit a letter commenting on Basel's Consultative Document on the Revised Basel III Leverage Ratio Framework.
CONTINUE READINGFOA Letter to BIS on Capital Charges on CCP Exposure
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