March 13 2019
Comments on Revisions to leverage ratio disclosure requirements
The Basel Committee’s additional leverage ratio disclosure requirements are designed to reflect its concerns about “window-dressing”. The Basel Committee would like to see averaged values disclosed on the basis of values calculated daily. In the view...Mehr
June 20 2018
Comments on Minimum Capital Requirements for Market Risk
On March 22, 2018, the Basel Committee on Banking Supervision issued the “Revisions to the minimum capital requirements for market risk” for consultation ...Mehr
September 15 2016
GBIC on Basel IV negotiations: great danger of German banks being placed at a considerable...
The member associations of the German Banking Industry Committee (GBIC) warn that the ongoing Basel IV negotiations could place German banks at a considerable disadvantage.Mehr
August 31 2016
Comments on Notice 2016-42 (proposed changes to qualified intermediary agreements)
The new rules in section 5.03(B) of the proposed QI agreement provide that the LOB declaration (which may be used by entities that are not fiscally transparent to document their status together with “alternative” documentary evidence.Mehr
June 3 2016
Comments on Consultative Document on Standardised Measurement Approach for Operational Risk (BCBS...
In autumn 2015, the BCBS announced that it would withdraw the AMA for operational risk. It stated that the rationale for dropping the AMA would be explained in the BCBS’s new consultative document. In our view, however, the consultative document does...Mehr