The Clearing House filed a comment letter in response to the Agencies’ April 8 proposed revisions to the denominator of the Supplementary Leverage Ratio. The Clearing House continues to support the fundamental notion of a leverage capital ratio that is intended and functions as a backstop floor to a risk-based approach to capital, and therefore generally supports the U.S. proposed revisions to the extent they promote a consistent leverage ratio calculation across jurisdictions. The letter requests that the Agencies consider further clarifications of, or modifications to, the treatment of certain exposures to ensure the measure of exposure is consistent with actual economic exposure and the U.S. supplementary leverage ratio continues to function in practice as a backstop floor rather than as a binding capital constraint. Furthermore, the areas that TCH believes merit further consideration include: (i) the conditions for netting derivatives and repo-style transactions, (ii) the eligible offsets for written credit derivatives, (iii) the methodology used to measure exposure for forward-starting repurchase agreements, and (iv) the scope of other exposures that are treated as off-balance sheet and, therefore, subject to credit conversion factors.
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