Recovery and Resolution Management



GFMA, BPI and IIF Submit Joint Response to BIS regarding Monitoring the Technical Implementation of the FSB TLAC Standard

August 2018  |  Correspondence  |  Press Releases

GFMA, Bank Policy Institute (BPI), and the Institute of International Finance (IIF) provide this joint trades letter in response to the request of the Financial Stability Board (FSB) to submit views on the technical implementation of the FSB’s standard on the adequacy of total loss-absorbing and recapitalization capacity for Global Systemically Important Banks (G-SIBs) in resolution the Total Loss-Absorbing Capacity (TLAC) standard.

GFMA and AuSF Submit Comments to the SEC Regarding the Re-Opening of Comment Period for Asset-Backed Securities Release

June 2015  |  Correspondence  |  Press Releases

GFMA and the Australian Securitisation Forum (AuSF) provide comments to the SEC regarding proposed revisions to Regulation AB under the U.S. Securities Act of 1933 (Regulation AB).

The Securities and Exchange Commission is re-opening the comment period for the Asset-Backed Securities Releases (Release Nos. 33-9552; 33-9244; File No. S7-08-10).

GFMA/IIF Final Response to FSB Consultation on Sharing with Non-CMG Host Authorities

May 2015  |  Correspondence  |  Press Releases

GFMA with the Institute of International Finance (IIF) provides comments to the Financial Stability Board (FSB) in response to the FSB consultative document on cross-border recognition of resolution action and on guidance on cooperation and information sharing with host authorities of jurisdictions not represented on CMGs where a G-SIFI has a systemic presence.

GFMA and other Associations Submit Comments to the BCBS on the Revised Standardized Approach for Market Risk

April 2014  |  Correspondence  |  Press Releases

GFMA, the Institute of International Finance (IIF) the International Swaps and Derivatives Association, Inc (ISDA) provide comments to the Basel Committee on Banking Supervision (BCBS) on the revised Standardized Approach for Market Risk.

The industry believes that the Sensitivity Based Approach (SBA), as put forward by the BCBS, constitutes a significant improvement to the previous version of the methodology and is in line with industry recommendations on leveraging upon existing validated risk metrics to calculate the market risk capital requirements.

The Advanced Cash Flow Approach (ACFA) methodology, on the other hand, is not computationally supported by existing infrastructure, since cash flow data are not captured at the trade level. As a result, industry members would require extensive resources to adhere to currently proposed regulatory timelines whilst achieving little in terms of enhancing the risk sensitivity of output metrics. This would be particularly onerous for smaller organizations.

GFMA Letter to the Editor-Financial Times: Start by endorsing principle of comity

March 2014  |  Correspondence  |  Press Releases

GFMA Chief Executive Simon Lewis writes to the editors of the Financial Times calling for G20 finance ministers and financial heads of all nations to formally endorse the robust application of the international principle of comity – where the home regulator defers to the host regulator where the latter’s rules are consistent with the G20 recommendations and best practices.

GFMA Submits Comments to IOSCO on Recommendations on Foundational Principles for Global Coordination in Cross-Border Regulation

March 2014  |  Correspondence  |  Press Releases

GFMA provides comments to the International Organization of Securities Commissions (IOSCO) offering recommendations on foundational principles for global coordination in cross-border regulation. IOSCO is creating a task force aimed at addressing cross-border regulatory coordination issues (the Task Force).

GFMA is supportive of the Task Force’s stated intention of issuing a public consultation paper focused on cross-border reform efforts and hosting public industry meetings for continued dialogue; and believes IOSCO can and should play an integral role in promoting coordination. Consequently, in advance of the Task Force’s consultation paper, GFMA writes to highlight several issues currently impacting cross-border regulatory coordination, which it believes are immediately actionable by IOSCO.

GFMA and Other Associations Submit Comments to the FDIC on the Single Point of Entry Strategy

February 2014  |  Correspondence  |  Press Releases

GFMA, SIFMA, The Clearing House Association L.L.C. (The Clearing House), the American Bankers Association, the Financial Services Roundtable and the Global Financial Markets Association provided comments to the Federal Deposit Insurance Corporation on their notice entitled Resolution of Systemically Important Financial Institutions: The Single Point of Entry Strategy.

The Notice describes the FDIC’s single-point-of-entry (SPOE) recapitalization within resolution strategy for resolving global systemically important banking groups (G-SIBs) with top-tier U.S. parent companies under Title II of the Dodd-Frank Wall Street Reform and Consumer Protection Act and requests comments on certain details and issues regarding how the FDIC would expect to carry out the SPOE Strategy with respect to U.S. G-SIBs.

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