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Capital

Response to the BCBS consultation on revised Basel III leverage ratio framework and disclosure requirements - 20/09/13

The IBFed appreciates this opportunity to comment on the Basel Committee on Banking Supervision (BCBS) proposal to revised Basel III leverage ratio framework and disclosure requirements. Please click here to read the full response.

 

 

Commenting on Basel Committee proposals for new capital disclosure requirements - 13/03/12

IBFed has offered broad support for proposals from the Basel Committee to enhance the disclosures banks make to their investors on their capital positions but, in doing so, has identified issues to be resolved with the proposed approach before it can be implemented. Please click here to read the full letter.

 

 

IBFed responds to Basel consultative document on G-SIBs -26/08/11

IBFed has responded to the Basel Committee’s Consultative Document "Global systemically important banks: Assessment methodology and the additional loss absorbency requirement".
While supporting the objective of the paper and the need to reduce the probability and the impact of any failure of G-SIBs, we expressed concern about the imposition of a surcharge, at least not at such high levels. And we pointed out the importance of understanding both the effect and interplay of new requirements and their potential to affect the pace of financial recovery and future economic growth, in advance of adding an additional requirement. We also underlined that it is essential to re-assess the proposed framework for the G-SIB assessment methodology and the additional loss absorbency requirements at a later point in time.The IBFed letter is available here.

 

 

IBFed responds to Basel consultative document on Operational Risk – 12/04/11 

IBFed has responded to consultative documents from the BCBS regarding operational risk: the Sound Practices for the Management and Supervision of Operational Risk, and Operational Risk – Supervisory Guidelines for the Advanced Measurement Approaches.  In the response to the Sound Practices consultation, IBFed offered three recommendations to enhance the paper: (1) Include a specific supervisory expectation that financial regulatory agencies should take into account the nature, size, complexity and risk profile of a bank when evaluating its implementation of the operational risk principles; (2) Avoid process-driven board directives in the operational risk principles and do not require the board to take on roles that may detract and conflict with the board’s strategic oversight responsibilities; and (3) Ensure that all principles included in the paper are risk-based and not prescriptive. 

In the letter commenting on the Supervisory Guidelines, IBFed welcomed the efforts of the Basel Committee’s Standards Implementation Group to develop consistent practices for measurement of operational risk and provided technical contributions to enhance the utility of the guidelines.

The IBFed comment letter on the Sound Practices for the Management and Supervision of Operational Risk is available here and the IBFed comment letter on Operational Risk – Supervisory Guidelines for the Advanced Measurement Approaches for is available here.

 

 

BCBS consultation paper on countercyclical capital buffers – 20/09/10

IBFed has responded to the Basel Committee on Banking Supervision’s (BCBS) recent consultation paper on countercyclical capital buffers.  In doing so, IBFed made a point of stressing that such buffers should be seen as one of a range of measures that could be used to alleviate the risks caused by excessive credit growth.  Other measures which could be equally or more appropriate include forward looking provisioning and more rigorous stress testing within Pillar 2.  The response also suggests that the Basel Committee considers the adoption of a single variable capital buffer in place of the complex system of multiple buffers currently suggested.  A single variable capital buffer would reduce this complexity whilst maintaining the flexibility for the Basel Committee to set the size and dynamics of the buffer by reference to its objectives.

The IBFed response is available here.

 
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