GFMA Submits Comments to the FSB on Consultative Document - Recovery and Resolution Planning
7 December 2012
GFMA provides comments to the Financial Stability Board (FSB) on the Consultative Document, Recovery and Resolution Planning: Making the Key Attributes Requirements Operational.
GFMA strongly agrees with the objective of the Consultative Document, and appeciates the FSB’s efforts to monitor and assess how well the Key Attributes are being complied with across jurisdictions. In addition, GFMA believes that progress on orderly resolution regimes should reduce the amount of any applicable G-SIFI surcharge. If a G-SIFI is resolvable, then the need for a surcharge premised on the lack of resolvability is substantially decreased and therefore any surcharge should be commensurably reduced.