A broad coalition of industry groups urged regulators to exclude client collateral when calculating the total assets of banks, and argued that an unchanged leverage ratio would "reduce access to clearing and undermine one of the main goals of financial reform."
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A number of financial services associations called for regulatory agencies to do "substantial additional work" on the Basel Committee on Banking Supervision's (“BCBS”) proposed framework, in advance of the U.S. consideration of the Fundamental Review of the Trading Book ("FRTB") rules. In a letter to the U.S. Department of the Treasury, the Office of the Comptroller of the Currency, the Federal Reserve Board of Governors and the FDIC, SIFMA et. al., warned of “potentially very negative impact[s] that the FRTB rules would have on the American financial markets, particularly as related to
Several financial services associations submitted comments to the Board of Governors of the Federal Reserve System in response to a proposal to impose total loss-absorbing capacity, long-term debt and related "clean holding company" requirements on global systemically important banking groups.
Several international trade associations objected to the Basel Committee on Banking Supervision's proposed revisions to the Basel III leverage ratio framework.
An ISDA-commissioned review of the "empirical academic literature" concluded that single-name credit default swaps ("CDS") have a "positive impact on the supply of credit to many reference entities underlying traded CDS."