The Clearing House (TCH) filed a comment letter with the BCBS in response to its Consultative Document on proposed changes to the G-SIB surcharge assessment framework. In the letter, TCH expresses serious concerns about the proposed change to the substitutability category, which would disproportionately and adversely affect four U.S. banks. TCH also details the broader framework’s conceptual and methodological flaws and calls for the BCBS to comprehensively revise the framework to reflect the actual systemic risks posed by G-SIBs, and thereby align it with its stated objectives.
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