The Clearing House (TCH), SIFMA, FSR, and the IIB (Associations) commented on the Basel Committee’s November 2015 consultation addressing the treatment under the Basel III capital framework of internationally active banks’ holdings of TLAC instruments of G-SIBs. Specifically, the Associations argue that the Basel Committee’s proposal should: (i) include an exemption for market-making activities; (ii) the cross-holdings deduction should conform to the symmetric “like-for-like” principle of the Basel III capital framework’s corresponding deduction approach; (iii) eliminate the proposal’s inclusion within deductible debt of instruments that rank pari passu with TLAC debt but themselves are not eligible for inclusion in TLAC debt; and (iv) increase Basel III’s 10% CET1 threshold for non-significant investments in the capital of unconsolidated financial institutions assuming the final approach retains the proposal’s asymmetric treatment of holdings of TLAC debt (deducting holdings of TLAC debt that are not regulatory capital against Tier 2 capital),and particularly if it fails to include a broad market-making exemption.
Regulatory Reporting and Accounting
BPI and IIB Comment on Federal Reserve Proposal to Revise FR Y-7Q Capital and Asset Report for Foreign Bank Organizations
BPI and IIB Comment on Federal Reserve Proposal to Revise FR Y-7Q Capital and Asset Report for Foreign Bank Organizations
Bank Capital and Stress Testing
DFAST 2022: Volatility, Capital Increases, and the Implications for the U.S Economy
DFAST 2022: Volatility, Capital Increases, and the Implications for the U.S Economy
Bank Capital and Stress Testing
BPI Statement on the Federal Reserve’s Release of the 2022 Stress Test Results
BPI Statement on the Federal Reserve’s Release of the 2022 Stress Test Results
Bank Capital and Stress Testing
Potential Costs Of Banning Capital Distributions By Banks In Bad Times
Potential Costs Of Banning Capital Distributions By Banks In Bad Times
Bank Capital and Stress Testing
A Modification to the Basel Committee’s Standardized Approach to Operational Risk
A Modification to the Basel Committee’s Standardized Approach to Operational Risk
Digital Assets
BPI Comments on Treasury Department Review of Digital Assets in Response to Executive Order
BPI Comments on Treasury Department Review of Digital Assets in Response to Executive Order
Community Reinvestment Act
BPI Comments on Federal Banking Agencies’ Community Reinvestment Act Proposal
BPI Comments on Federal Banking Agencies’ Community Reinvestment Act Proposal
