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May 25 2018

Comments on the BCBS Pillar 3 disclosure requirements – updated framework

The Basel Committee on Banking Supervision (BCBS) issued on 27 February 2018 a consultative document on the updated Pillar 3 disclosure requirements framework ...

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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.

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July 15 2016

Dividend equivalent payments: Request to postpone the implementation date of Section 871(m)

We welcome the release on 1 July 2016 of Notice 2016-42 containing a revised proposed qualified intermediary agreement. Unfortunately, the notice fails to answer most of our open questions concerning the treatment by qualified derivatives dealers of...

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October 4 2013

Comments On the Consultation Document “Revised Basel III leverage ratio framework and disclosure...

On 26 June 2013, the Basel Committee for Banking Supervision published its Consultation Document entitled “Revised Basel III leverage ratio framework and disclosure requirements“. We appreciate the present opportunity to share our comments.

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