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.