The EACB welcomes the opportunity to comment on the revised text of the Basel III framework on the Net Stable Funding Ratio (NSFR) from January 2014.
We believe that in some ways the current calibration of the NSFR better reflects the stability of refinancing, due in particular to two principles:
- long-term refinancing operations have a higher stability than short term funding;
- deposits from retail and SME customers are more stable than wholesale deposits for the same duration.
However, we believe that the text does not fully reflect these principles in relation to the specific role played by central institutions of cooperative banking networks.
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