Capital

FIA has filed two comment letters responding to US federal banking regulators' proposals to revise capital standards for Category I and II banking organizations, including the implementation of Basel III’s enhanced risk-based approach (ERBA) in the US, as well as proposed changes to the Federal Reserve’s capital surcharge for US global systemically important bank holding companies (G‑SIBs). 

FIA's response outlines proposals for a better rulemaking process in the EU and lists examples where an unlevel playing field between EU banks and global competitors has been identified. It also suggests a different regime for the determination of QCCP status for capital purposes, advocates for a change in the GSIB treatment of the principal model for cleared OTC derivatives, and calls for a permanent central bank reserves exemption from the leverage ratio.

FIA is pleased that the US bank regulators have recognized our concerns about the potential impact of disproportionately high bank capital requirements on agriculture, energy and other end-users. These market participants rely on banks to provide clearing services for hedging risk, particularly during times of stress.

Following the US the federal bank regulatory agencies jointly issuing answers to frequently asked questions to clarify the capital treatment of tokenized securities, FIA and other financial trade associations welcomed the news and sought further action.

The FIA-sponsored European Agent Trustee Model (EATM) has gone live at LCH Ltd for its SwapClear service, marking an important milestone in a multi-year project between FIA, a consortium of bank clearing members, two European clearinghouses, and external counsel. 

FIA has submitted a comment letter to the CFTC and SEC supporting FICC and CME's proposed arrangement for cross-margining of customer trades in treasuries and treasury futures with offsetting risk. The proposed arrangement is under review at both the CFTC and SEC.