The Clearing House (TCH) submitted a comment letter to the Basel Committee in response to its second consultative document proposing guidelines for the identification and management of step-in risk. TCH’s letter is supportive the Basel Committee’s revisions to the proposed framework, however notes numerous aspects of the proposal that need to be updated in order to achieve the Basel Committee’s objectives of sensitivity to residual step-in risk and simplicity of the framework. Specifically, TCH’s comment letter urged the BCBS to require national supervisors to analyze the extent to which post-crisis regulatory reforms and other mechanisms have mitigated step-in risk to determine whether there is any residual step-in risk that warrants implementation of the Basel framework, revise the scope of definitions, exclude entities from the step-in risk analysis, and provide national supervisors with greater flexibility, including with respect to the proposed reporting templates.
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