The Clearing House (TCH), along with SIFMA, the FSR, the ABA, CRE Finance Council, the IIB, and ISDA filed a supplemental NSFR comment letter with the U.S. banking agencies. Specifically, the comment letter highlights a number of differences between the EU’s NSFR Proposal and the U.S. NSFR Proposal, highlighting ten “primary differences” between the EU proposal and U.S. proposal. Most notably, while the U.S. Proposal would assign a 5% RSF to unencumbered Level 1 securities, the EU Proposal would generally assign a 0% RSF. Moreover, the U.S. Proposal would become effective on January 1, 2018, while the EU Proposal is expected to enter into force beginning in 2019 at the earliest. The letter also identifies fifteen “other technical and potential differences”, which each involve either an area of technical divergence between the proposals or a potential difference between the proposals depending on how certain terms are interpreted in practice.
You Might Also Be Interested In...
Systemic Risk & TBTF U.K. Pension Fund Debacle Illustrates How Government-Created Moral Hazard Can Lead to Systemic Risk
Bank Liquidity How the Overnight Reverse Repurchase Agreement Facility Could Derail the Fed’s Path to Getting Smaller
Bank Liquidity The Bank of England Just Released Its Plan for Getting Smaller. The Fed Could Learn from it.
Bank Liquidity Imposition of SPOE and TLAC Requirements on Large Regional Banks is Unnecessary to Promote Financial Stability
More Posts by This Author
Supervision & Enforcement FDIC’s Proposed Changes to Supervisory Appeals System Fall Short of Progress
Bank Capital and Stress Testing Governance and Authority of the Basel Committee on Banking Supervision
Cybersecurity Financial Trades Call for Accessible, Functional and Simple Cyber Incident Reporting Rules