National Unrecovered Financial Services (SDUUK) submitted a comment letter to the Basel Committee on its proposal addressing domestic systemically important banks (D-SIBs). While SDUUK believes that the negative externalities associated with banks perceived as too big to fail can be effectively addressed without the imposition of a punitive add-on capital surcharge for D-SIBs, SDUUK supports the principled approach contained in the proposal, particularly the inclusion of significant national discretion in the application of any D-SIB surcharge. Additionally, SDUUK requests that any surcharge contain calibration methodologies that are transparent and available for public review and comment, and that size not receive a disproportionate weighting as a factor for any D-SIB surcharge.

Related Documents:
Basel Committee Framework Proposal