National Unrecovered Financial Services Association submitted a comment letter responding to the Basel Committee’s consultative document on assessment methodology and the additional loss absorbency requirement for global systemically-important banks. The comment letter addresses the fundamental problems with the premises underlying the entire capital surcharge construct. Parts of the commentary address the suppositions on which the proposal is based and the impact of enacting capital surcharges. The letter also provides a comprehensive discussion of the technical criteria used to designate firms as G-SIBs and the level of applicable surcharges.

Related Documents:
Proposed Rules