GFMA provides comments to the Financial Stability Board (FSB) and the Basel Committee on Bank Supervision (BCBS) on the implementation of prudential standards. The post‐crisis international regulatory framework represents a major step forward from that which existed prior to the financial crisis. GFMA shares concerns that as the implementation phase begins for many of these regulatory reform initiatives, however, instances of divergence from agreed frameworks have increased. Some jurisdictions have also adopted or are considering additional reforms beyond international consensus (e.g., structural banking reforms). Inconsistent prudential standards, including variations in supervisory practices, and a trend toward regulatory fragmentation could increase regulatory arbitrage, undercut efforts to develop a credible cross‐border resolution regime, and undermine international cooperation on policymaking.
