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GFMA, the Institute of International Finance (IIF), the International Swaps and Derivatives Association (ISDA), and the Commercial Real Estate Finance Council (CREFC) provide comment to the Basel Committee on Banking Supervision (BCBS) on their December 2014 Consultative Document, “Capital Floors: the design of a framework based on standardized approaches.”
The Associations support the work of the Committee and specifically of the Task Force for Simplicity and Comparability (TFSC) aimed at conducting a comprehensive review of the capital framework and its overall calibration and taking stock of the multiple changes thereto in the course of the past 5 years. The Associations are equally supportive of the Committee’s goal to remove undue complexity and improve the comparability of banks’ capital requirements. The Joint Associations welcome the opportunity to contribute to the discussion on capital floors.