GFMA with IIF and ISDA submitted a joint response to the BCBS G-SIB Window Dressing consultation.

GFMA submitted a response letter to the FSB in regarding its consultation on evaluation of too-big-to-fail (TBTF) reforms for banks. The response outlined key achievements in addressing TBTF, the areas that warrant further analysis and the other questions that should be asked in order to complete the evaluation.

GFMA submitted a response to the Basel Committee's  finalization of revisions to the Globally Systemically Important Bank: Revised Assessment Methodology and the Higher Loss Absorbency Requirement.

GFMA, Bank Policy Institute (BPI), and the Institute of International Finance (IIF) provide this joint trades letter in response to the request of the Financial Stability Board (FSB) to submit views on the technical implementation of the FSB’s standard on the adequacy of total loss-absorbing and recapitalization capacity for Global Systemically Important Banks (G-SIBs) in resolution the Total Loss-Absorbing Capacity (TLAC) standard.

GFMA response to BCBS Consultative Document: Global systemically important banks - revised assessment framework.

GFMA with the Institute of International Finance (IIF) provides comments to the Financial Stability Board (FSB) in response to the FSB consultative document on cross-border recognition of resolution action and on guidance on cooperation and information sharing with host authorities of jurisdictions not represented on CMGs where a G-SIFI has a systemic presence.

GFMA and the Institute of International Finance (IIF) provide comments to the Financial Stability Board (FSB) on the FSB's publication of a term sheet (TS) for Total Loss Absorbing Capacity (TLAC) for Global Systemically Important Banks (G-SIBs).

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 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, SIFMA, The Clearing House Association L.L.C. (The Clearing House), the American Bankers Association, the Financial Services Roundtable and the Global Financial Markets Association provided comments to the Federal Deposit Insurance Corporation on their notice entitled Resolution of Systemically Important Financial Institutions: The Single Point of Entry Strategy.

The Notice describes the FDIC’s single-point-of-entry (SPOE) recapitalization within resolution strategy for resolving global systemically important banking groups (G-SIBs) with top-tier U.S. parent companies under Title II of the Dodd-Frank Wall Street Reform and Consumer Protection Act and requests comments on certain details and issues regarding how the FDIC would expect to carry out the SPOE Strategy with respect to U.S. G-SIBs.

See also:

78 FR 76614 - RESOLUTION OF SYSTEMICALLY IMPORTANT FINANCIAL INSTITUTIONS: THE SINGLE POINT OF ENTRY STRATEGY

GFMA, the Institute of International Finance (IIF), The Clearing House Association L.L.C. (TCH), and the Federation of Finnish Financial Services (FFI) provide comments to the Financial Stability Board (FSB) on the FSB Common Data Template Workshop held 2-3 October 2013, which focused on Phases 2 and 3 of the FSB G-SIB Common Data Template (CDT), organized by the FSB Data Requirements Workstream (DRW).

This letter starts with a reiteration of the major themes the industry raised at the workshop, followed by detailed discussions of our comments on the Phases 2 and 3 templates.

GFMA provides comments to the Financial Stability Board (FSB) responding to the FSB Consultation Document: Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions (Discussion Paper).  

GFMA summarises the key concerns and comments raised by GFMA members with respect to Appendix III of the Discussion Paper entitled “Client asset protection in resolution.”  Specifically, GFMA's comments focus on the definition of client assets and on client asset segregation rather than on resolution tools outlined in the Discussion Paper.

GFMA, the International Institute of Finance (IIF), the International Swaps and Derivatives Association, Inc. (ISDA), and The Clearing House (TCH) provide comments to the Financial Stability Board (FSB),  the Committee on Payment and Settlement Systems (CPSS) of the Bank for International Settlements (BIS), and the International Organization for Securities Commissioners (IOSCO) on the FSB Consultation Document: Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions and the CPSS-IOSCO Consultative Report: Recovery of Financial Market Infrastructures (FMIs). 

Effective recovery, continuity and resolution mechanisms for FMIs are critical to the efficient operation and sustainability of the financial markets. It would be difficult, if not impossible, to maintain financial stability if essential services provided by FMI entities were to cease.

GFMA provides comments to the Financial Stability Board (FSB) in response to the FSB's Consultative Document:Information sharing for resolution purposes, 12 August 2013.

GFMA is strongly supportive of the work of the FSB towards establishing an effective cross-border recovery and resolution framework and the Key Attributes of Effective Resolution Regimes for Financial Institutions. Cross-border cooperation is a crucial requirement for effective cross-border resolution and GFMA strongly supports efforts to strengthen and facilitate greater cross-border cooperation in this area.  In that context, GFMA shares its expertise in response to the Consultative Document.

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.

GFMA provides comments to the U.S. Board of Governors of the Federal Reserve System on a proposed rule, Enhanced Prudential Standards and Early Remediation Requirements for Foreign Banking Organizations (FBOs) and Foreign Nonbank Financial Companies; Docket No. R−1438; RIN 7100 AD 86.

GFMA recognizes that the profile of the U.S. operations of some FBOs has changed substantially in recent years and understands the Federal Reserve’s concerns about the financial stability risks that global financial institutions can pose to host country financial systems.  However, GFMA believes that the proposed rule will exacerbate, rather than mitigate, these financial stability risks and harm the global economy.

GFMA provides comments to the Secretariat of the Basel Committee on Banking Supervision on the recent consultative paper, A framework for dealing with domestic systemically important banks (the D-SIB framework). 

GFMA and the Institute for International Finance (IIF) provide comments to the Finacial Stability Board (FSB) on the G-SIB Common Data Template (CDT) proposal.  The groups encourage the FSB to:

• Formally adopt principles that should guide information collection
• Form an industry advisory group to facilitate dialogue with the industry on the development of the data template
• Launch the common data template using an observation period
• Clarify and consult on the governance arrangements regarding use and confidentiality of the data
• Consider forming a permanent supervisory reporting board to oversee international data initiatives

GFMA with their European affiliate, the Association for Financial Markets in Europe (AFME),  authored a briefing note on Global Systemically Important Financial Institutions.

Introduction 

Global Systemically Important Financial Institutions, or G-SIFIs, have become an area of focus for international policymakers.  The G20 is driving the development of a new regulatory framework at a political level and has tasked various agencies with creating more detailed approaches.  The concern of policymakers is that G-SIFIs are too-big-to-fail, potentially forcing taxpayers to bear the costs of any failures.           

The policy framework for banks classified as G-SIFIs (known as Global Systemically Important Banks, or G-SIBs) has been developed more quickly than for other parts of the financial sector.  The initial list of G-SIBs has been published (see box below) using a methodology developed by the Basel Committee (BCBS).  These banks face new capital requirements and are required to develop resolution plans, while the Financial Stability Board (FSB) has consulted on an enhanced data template for G-SIBs.

While the Global Financial Market Association (GFMA), of which AFME is a member, strongly supports the goal of the Basel Committee to promote financial stability, GFMA has a number of concerns with the proposed G-SIB capital buffers including: whether the benefits exceed the cost of reduced economic growth, the lack of clear and well-defined offsets against the capital buffers for improved resolution regimes, and transparency and methodological issues.

This discussion note focuses on the proposals under consideration by the FSB and the Basel Committee on Banking Supervision (BCBS) relating to the establishment of additional loss absorbing capacity for SIBs.

GFMA provides comments to the Secretariat of the Basel Committee on the July 19, 2011 consultative document: “Global Systemically Important Banks: Assessment Methodology and the Additional Loss Absorbency Requirement."

The Global Financial Markets Association (GFMA), The Clearing House Association (TCH), the American Bankers Association (ABA), The Financial Services Roundtable (FSR), the Institute of International Bankers (IIB), and the Institute of International Finance (IIF) collectively, welcome the opportunity to comment on the Consultative Document on Effective Resolution of Systemically Important Financial Institutions published by the Financial Stability Board (FSB) on July 19, 2011 (Consultative Document).

The groups strongly agree with the overall objective of the Consultative Document – that authorities in all relevant jurisdictions should have the capacity to resolve systemically important financial institutions (“SIFIs”) without systemic disruption and without exposing the taxpayer to the risk of loss, within a reasonable timeframe. Taxpayer-funded bailouts have been chosen in the past, including during the recent global financial discrimination will be an impediment to cross-border resolutions of G-SIFIs. Instead, foreign and domestic deposits, and foreign and domestic depositors, should be treated as a single class in any depositor preference law.

GFMA, American Bankers Association (ABA), The Clearing House, and the Financial Services Roundtable provide comments to the Financial Stability Board on the Consultative Document: Understanding Financial Linkages: A Common Data Template for Global Systemically Important Banks, 6 October 2011.