The members of EACB appreciate the opportunity to comment on the Basel Committee’s consultative document on revisions to leverage ratio disclosure requirements.
Hervé Guider, EACB General manager, commented: "The EACB members understand the aim to design disclosure requirements that provide relevant information while preventing risks of regulatory arbitrage, however we believe that the proposals of the Committee are not fit for purpose and will likely only lead to an increased complexity of the framework. We believe that alternative and more targeted and cost effective solutions are possible to address window dressing concerns."
In the EACB view, the BCBS should rather set principles for supervisors to monitor and eventually engage in supervisory dialogue as we agree that “window dressing” the LR (and other ratios) is not appropriate. Nevertheless, if a rule based approach were to be identified, we believe it should be at the very least significantly adjusted in terms of scope and methodology.
Volker HEEGEMANN, Head of Legal department, email@example.com
Marco MANCINO, Deputy Head of Lega department, firstname.lastname@example.org