GFMA with IACPM, IIF, and SFA submitted a joint industry response to a BCBS Technical Amendment on Capital Treatment of Securitisations of Non-Performing Loans.

GFMA submitted feedback to the the European Commission's Technical Expert Group's June report on a sustainable finance taxonomy for the European Union.

GFMA has published the results of a survey of global financial institutions' sustainable finance strategies and activities. The survey, conducted in May and June of 2019, is based on the anonymized and aggregated responses of 22 of the largest globally active financial and capital market participants. The findings of this survey will be helpful to institutions to benchmark against their peers and also to help inform future policymaking.

New Financial has published a new report, commissioned by the Global Financial Markets Association (GFMA), entitled “The New Financial Global Capital Markets Growth Index.” The purpose of the report is to provide an in-depth review and comparison of national and regional capital markets across the globe in terms of market size, depth, and access to pools of capital. GFMA commissioned New Financial to prepare the report to underscore the role markets can play in supporting sustainable economic growth around the world by diversifying the sources of available funding for companies, improving productivity through more efficient capital allocation and better risk management, increasing the capacity of economies to absorb economic shocks, and funding more sustainable pension systems. The report also identifies challenges and provides recommendations for jurisdictions to develop and expand capital markets as a source of funding and investment.

GFMA, IIF, ICMA and Australian Securitsation Forum Submit Comments to the Basel Committee and IOSCO on STC criteria for short-term securitisations.

GFMA and the Institute of International Finance (IIF) provide comments to the Task Force on Climate-related Financial Disclosures, Financial Stability Board, Bank for International Settlements,

GFMA drafted and today submitted comments to the Basel Committee on its Step-In Risk consultation (joined by CREFC, CREFC Europe, the Real Estate Roundtable).  The Basel Committee issued this consultation to address the risk that a bank would ‘step in’ to provide voluntary, non-contractual support for a transaction (such as what banks did with SIVs or credit card ABS in the crisis).  The Basel Committee’s proposal would require a bank to examine all off-balance sheet vehicles and other relationships which are not currently capitalized and, if step-in risk indicators are there, hold capital for them as if they were on-balance sheet.  The proposal is very expansive and could require massive amounts of effective consolidation if read broadly.  GFMA/CREFC/RER’s position is that the proposal is not needed given the massive amount of regulatory change (importantly including changes to off-balance sheet accounting rules, the Volcker Rule in the US, and other regulations) that have largely addressed this problem.  We do not believe step-in risk is a material issue at this point and suggest the Basel Committee should forego implementing new rules in this area.  We also raise significant concerns with the lack of clarity and expansive breadth of the proposal.  

See also:
Identification and measurement of step-in risk - consultative document

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 and its regional members, SIFMA, AFME and ASIFMA, provide comments to the Organisation for Economic Co-operation and Development (OECD) Centre for Tax Policy and Administration to express concerns regarding the current timeframe for both implementing and ensuring compliance with the Common Reporting Standard (CRS) for automatic exchange of information on financial accounts.

Related:
GFMA White Paper on Implementation of the OECD's Common Reporting Standard - 5 February 2015

GFMA, the International Capital Market Association (ICMA), the Institute of International Finance (IIF) and International Swaps and Derivatives Associations (ISDA) (together the "Joint Associations") responded to the Consultation Document entitled "Criteria for identifying simple, transparent and comparable securitisations" published by the Basel Committee on Banking Supervision (BCBS) and the Board of the International Organization of Securities Commissions (IOSCO) on 11 December 2014. 

This white paper reflects the views SIFMA, AFME and ASIFMA, collectively, the “Working Group” with regard to implementing the OECD’s Common Reporting Standard (CRS).

Related:
GFMA Submits Comments to OECD Regarding Implementation of the Common Reporting Standard Background - 16 March 2015

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.

GFMA and other associations provides further information to the Basel Committee for Banking Supervision (BCBS or the Committee) for BCBS to consider as they move toward completing work on the proposals set out in the second consultative document, "Revisions to the Basel securitisation framework."

The groups remain concerned that the current proposals will not meet the Committee's stated objective of comparability, resulting instead in capital requirements that are neither comparable among calculation methods nor proportionate to risks.

It is essential that the timetable for finalisation of the proposed framework is extended to address those shortcomings. Additional work should be undertaken to refine the calibration of the proposed framework and especially to improve the consistency of results between the internal ratings-based approach (IRBA), the external ratings-based approach (ERBA) and the standardised approach (SA). This should include gathering additional, more granular data and undertaking further analysis beyond what was provided in the QIS. In particular, we would recommend conducting analysis of data grouped by the market-defined asset classes of the underlying exposures (rather than according to the regulatory exposure categories). Further consideration should also be given to additional analytical work provided by the industry and referred to in the Joint Associations' comment letter dated 24 March 2014 (Comment Letter).

RCL has conducted an analytical study of certain data provided by a number of GFMA's member banks. These data are limited as explained in the Report, and the Report should be read and understood in that context. It is especially important to note that the Report does not advocate or support a particular calibration method or outcome, and in particular we do not intend that any of the implied p-values set out in the report should be used to calibrate the revised framework. Rather, the Report reveals a number of results that we respectfully ask the Committee to consider as they continue to work on the proposed revisions.

Related Material

RCL Report: Quantitative Impacts of BCBS 269 Securitisation Capital Approaches (August 8, 2014)

BCBS 269: "Revisions to the Basel securitisation framework" (December 21, 2013)

GFMA and Other Associations Submit Comments to the BCBS on the BSBC's Second Consultative Document on the Basel Securitisation Framework (March 24, 2014)

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 provides comments to the Basel Committee on Banking Supervision (BCBS) on proposals set out in the Consultative Document Basel III: the Net Stable Funding Ratio (NSFR) published by the BCBS on 11th January 2014 (Consultation Paper).

This letter sets out GFMA’s detailed points on securitisation only, and is intended to supplement the broader letter of even date submitted by the Institute of International Finance (IIF), the GFMA and others.

GFMA agrees with the BCBS that securitisation, prudently deployed and sensibly regulated, can make a very positive contribution to a bank’s overall liquidity management. GFMA requests that the Committee engage in a similar way with the industry in this, relatively new, context of the NSFR in order to achieve a treatment of high quality securitisation that accurately recognises its strong credit performance through and since the financial crisis as well as its benefits as a self-liquidating funding tool for the real economy.

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 and other associations provide a response to the Basel Committee for Banking Supervision (BSBC) on the BCBS' second consultative document, Revisions to the Basel Securitisation Framework (published 21 December 2013).The groups welcome the development of a simpler and more straightforward hierarchy of approaches, some reduction of risk weights for higher credit quality exposures, including reduction of the risk weight floor, recognition of credit protection provided by excess spread, preservation of existing flexibility in application of the Internal Ratings-Based Approach (IRBA), preservation of the Internal Assessments Approach (IAA), and requiring one rather than two qualifying credit ratings for application of the External Ratings-Based Approach (ERBA).

However, the groups believe that the proposed capital requirements for securitisation exposures, especially for higher quality exposures and for medium-term and longer-maturity transactions, remain much higher than justified by historical loss incidence in most asset classes, by comparison with other methods of finance or in relation to the capital requirements of the underlying asset pools. These excessive capital requirements will discourage banks from investing in or otherwise acquiring exposure to securitisation transactions. The groups recommend specific changes to certain of the modelling assumptions and parameters used in formulating and calibrating the approaches, as well as changes to the operating conditions for certain approaches and to the risk weight floor and capital cap provisions.

GFMA signed the letter with the follow groups: The Commercial Real Estate Finance Council (CREFC), the Commercial Real Estate Finance Council Europe (CREFC Europe), the Institute of International Finance (IIF), the International Association of Credit Portfolio Managers (IACPM), the International Swaps and Derivatives Association, Inc (ISDA), the Securitisation Forum of Japan (SFJ), and the Structured Finance Industry Group (SFIG).

GFMA provides comments to all G20 Finance Ministers in Support of Global, Consistent Standards and Meaningful Regulatory Reform. This letter addresses important developments related to implementation and global consistency of the G20s regulatory reform agenda which may risk divergence from consistent implemention.

GFMA provides comments to the Organisation for Economic Co-operation and Development (OECD) on the OECD's Action Plan for Base Erosion and Profit Shifting (BEPS).  GFMA shares concerns that certain aspects of the Action Plan could have unintended consequences for the financial services industry. In order to minimize the risk of possible unintended effects, GFMA requests that the OECD consider the potential implications of the action items for the financial services industry.

GFMA provides comments to the G20 Central Bank Governors voicing strong opposition to the EU's proposed financial transaction tax (FTT).  GFMA believes that, as currently designed, the proposed FTT will harm economic growth at a time of significant economic uncertainty by increasing government and corporate borrowing costs, and will undermine the effectiveness of monetary transmission channels.  In addition, the FTT would have unprecedented extraterritorial impacts, contrary to G20 principles and commitments.  In addition, the AFTT would have unprecedented extraterritorial impacts, contrary to G20 principles and commitments.

GFMA's Global Foreign Exchange Division (GFXD) authored a briefing note on the impact of the proposed European Union Financial Transaction Tax (FTT) on Foreign Exchange (FX) markets.

The related Press Release is available at the following link:
http://www.gfma.org/News/Item.aspx?id=494

Executive Summary

 The Foreign Exchange (FX) market underpins international commerce and investment by allowing governments, businesses, investors and individuals to convert one currency to another. In addition to FX Spot transactions, other FX Products (FX forwards, NDFs, FX swaps, FX options) enable participants to transact with certainty over the exchange rate and therefore the value of the transaction, whether for issuing a bond to international investors, purchasing raw materials abroad, exporting goods overseas, or protecting the value of pension investments made in other currencies. 

Europe is focused on restarting economic growth. The ability of European companies of all sizes to remain active on the global scene - by exporting European goods while securing a stable income at home despite volatility in currency markets - is crucial to this economic growth. FX Products are central to that ability.

To preserve the usefulness of FX markets, the proposed Financial Transaction Tax (FTT) should not create barriers or prevent European companies and investors from being active in international commerce and investment. The inclusion of these FX Products in the scope of any FTT would significantly raise the cost for end-users if they are to remain active in international commerce. Our analysis shows:

• For EU corporates, their FX transaction costs will rise by up to 700%. With just a single dealer a corporate based in the tax zone could see its annual FX transactions costs rise from $2.4m to $20.4m.
• For a pension fund or fund manager, the impact is even greater, due to the double-sided nature of the proposed tax. These users could see their transaction costs rise by around 1,500% and possibly by as much as 4,700%. For a pension fund manager whose annual FX transaction costs with a single dealer are currently $1.6m, this will mean that, once taxed, transaction costs would exceed $75m.

Imposing an FTT on these FX Products (FX forwards, NDF, FX swaps, FX options) may well cause companies and investors to move away from hedging the risk of their international activities, increasing their earnings volatility and business risk or pushing up costs that will reduce returns for investors. It risks discouraging them from being active in international commerce or creating costs that are a drain on firms’ financial resources that they could otherwise have deployed to fund their growth plans.

The European Commission3 has already recognised that including FX spot transactions in the FTT would infringe the movement of capital under The Treaty on the Functioning of the European Union and in 2011 raised concerns with regards including other FX Products. Given these other FX Products are used for the same purposes as spot transactions - for payments, investing and funding - we suggest that these FX Products – FX swaps, forwards, options and NDFs - should, as is already the case in relation to FX spot transactions, be excluded from the scope of any FTT proposal.

GFMA, the Australian Financial Markets Association (AFMA), the Investment Industry Association of Canada (IIAC), the Japan Securities Dealers Association, and the Korea Financial Investment Association (KOFIA) provide comments to all G20 financial ministers expressing their strong opposition to the EU's proposed financial transaction tax (FTT).  The groups believe the FTT would have unprecedented extraterritorial impacts, contrary to G20 principles, and would harm economic growth.

GFMA provides comments to the International Organization of Securities Commissions (IOSCO) on the consultation report entitled "Global Developments in SecuritisationRegulation" (the Consultation Report), and the corresponding proposed policy recommendations.

Securitisation market members of the Association for Financial Markets in Europe (AFME), the Securities Industry and Financial Markets Association (SIFMA) and Asia Securities Industry and Financial Markets Association (ASIFMA), working together as the Global Financial Markets Association (GFMA) provide comments to the Joint Forum in response to their July Report on Asset Securitisation Incentives.

GFMA provides comments to the Basel Committee for Banking Supervision (BCBS) requesting an extension of the comment due date of the Consultative Document on Revisions to the Basel Securitisation Framework.  GFMA appreciates the efforts of the the BCBS and its working group that produced the technical paper (the Technical Paper) and a proposed quantitative impact study (the QIS) in connection with the consultative document.  However, given the short period of time from the issuance of the Technical Paper and the QIS, and the meeting thereon, until March 15, 2013, when the comment period on the Consultative Document is due to expire, GFMA members are concerned that there is not sufficient time remaining before the Comment Due Date to adequately evaluate and comment on the Consultative Document.

GFMA provides comments to the Basel Committee for Banking Supervision (BCBS) on the Consultative Document, Revisions to the Basel Securitisation Framework published by the BCBS on 18 December 2012.  GFMA believes the starting assumptions of the Consultative Document are too narrowly drawn. The group notes that outside certain well-known and defined sectors, securitisations have performed well since the financial crisis. GFMA calls for a balanced, prudently calibrated and holistic policy response.

GFMA provides comments to the Secretariat of the Basel Committee on Banking Supervision (BCBS) on the consultative document:  Principles for the supervision of financial conglomerates.  GFMA supports the development of consistent and effective supervision of global financial firms, and welcomes the work of the Joint Forum on strengthening the supervision of financial conglomerates (FCs).

On 28th September 2011 European Commission President José Manuel Barroso unveiled the EU Commission’s proposal for an EU wide Financial Transaction Tax (FTT) which would take effect from 1st January 2014. The tax would be levied on all securities and derivative transactions executed within the EU. For Foreign Exchange (FX) instruments spot has been exempted from taxation, however cash (defined as FX forwards and swaps) and derivatives (defined as options) have been included.

 This study evaluates the impact of the proposed EU Financial Transaction Tax on European FX markets. We aim to quantify the impacts of the FTT on FX cash and derivative markets, both in terms of the transaction costs and the effects on the participants in these markets. Previous studies have shown that introducing an FTT results in the primary impacts of an increase in the cost to transact, geographic relocation of trading, substitution and a general reduction in notional turnover. In addition, the secondary impacts are a reduction in liquidity and increased market inefficiencies. This can lead to an increase in short-term price volatility and widening bid/ask spreads.

 

GFMA writes to express opposition to the imposition of a financial transaction tax (FTT), or other substitute form of the FTT.