“GFMA shares the Basel committee’s goal of ensuring the safety and soundness of the global financial system, which is critical to enhancing investor and consumer confidence. GFMA supports both properly calibrated capital requirements and a leverage ratio, both of which are a vital component of a resilient financial system.
“We believe, however, that the revised proposal issued by the Basel Committee on Banking Supervision would have negative unintended consequences that work at cross purposes to other important financial reforms. The proposed capital requirement comes on top of the Basel III risk weighted capital requirements, the liquidity coverage ratio and other measures designed to reduce risks in the system. This proposal does not work with these other measures and most instances works against them, or at least at cross purposes. Such a result is plainly at odds with the critical need for banking organizations to hold adequate levels of safe, highly liquid assets to manage unexpected customer demands and funding uncertainties.
“A disincentive to hold low risk assets is likely to cause a decline in liquidity in government securities and cash markets, diminish access to repurchase agreement (“repo”) funding and other securities financing, and negatively impact central bank monetary policy operations. In addition to impacting individuals and businesses, the government could also find it harder to borrow money. As liquidity dries up, investors will also find it harder to access a variety of investment products, restricting their ability to meet their financial goals.
“Additionally, the one-size-fits-all approach to calculating the leverage ratio may encourage banks to hold riskier assets that generate higher returns – this is fundamentally at odds with prudent risk management practices that aim to keep the financial system safe. Banks would be required to hold much more capital for their least risky assets, which will hamper their ability to lend to families who are looking to buy a home and businesses that want to expand and hire.
“In its comment letter, GFMA recommends modifications to the proposed rule to better address the Basel Committee’s overall objective. The suggested changes would also provide a more accurate reflection of bank exposures and return the leverage ratio to its original intended purpose as a backstop to risk-based capital requirements.
“GFMA urges the Basel Committee to adopt changes to the proposed framework to insure that banks can continue to nurture economic growth through monetary policies and provide the capital, credit and liquidity which families, businesses, investors and the government need to drive economic growth and job creation.”
The letter is available at the following link: http://www.gfma.org/correspondence/gfma-and-other-association-submit-comments-to-the-bcbs-on-basel-iii-leverage-ratio-framework-and-disclosure-requirements
The Global Financial Markets Association (GFMA) brings together three of the world’s leading financial trade associations to address the increasingly important global regulatory agenda and to promote coordinated advocacy efforts. The Association for Financial Markets in Europe (AFME) in London and Brussels, the Asia Securities Industry & Financial Markets Association (ASIFMA) in Hong Kong and the Securities Industry and Financial Markets Association (SIFMA) in New York and Washington are, respectively, the European, Asian, and North American members of GFMA. For more information, visit http://www.gfma.org