Global Correspondence

GFMA Submits Comments to the Basel Committee in Response to their Consultative Document: Definition of Capital Disclosure Requirements

GFMA provides comments to the Secretariat of the Basel Committee on Banking
Supervision (BCBS) in response to the Consultative Document: Definition of capital
disclosure requirements, 19 December 2011. 

GFMA believes the BCBS focus on post-2018 capital disclosures, taking more
time to agree on the specific modalities of that disclosure, and not implement
the transitional template. GFMA makes this suggestion for reasons including:

  • The value of the transitional templates are compromised by the
    uneven pace of implementation of rules governing Basel III, as well as revisions
    to and uncertainties about risk-weighted asset calculations.
  • It is difficult to evaluate the impact of this proposal
    without understanding the bigger picture of upcoming Pillar 3 revisions, as well
    as additional reporting and disclosure that will result from other international
    policy initiatives.
  • This proposal, as with any other reporting and disclosure
    proposals, should be subject to a cost/benefit review. One step that clearly
    reduces costs and enhances benefits is to ensure data definitions are
    harmonized where possible, within and across templates.


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