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
- 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.