Proposed Amendment to the Basel III Leverage Ratio Exposure Denominator

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FSR along with ABA, SIFMA, and ISDA generally support the proposal by the Federal Reserve, FDIC, and OCC to integrate portions of the Basel agreement into its final leverage ratio rule. The industry continues to suggest, however, that certain attributes of the rule should be amended so that it does not become the binding constraint on the capital planning of banks and bank holding companies. The trades suggest that certain types of assets should be excluded from the leverage ratio exposure measure. That way possible unintended consequences of the rule, such as lack of capacity for banks to hold deposits, will be avoided.

 

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FSR and its industry partners generally support the proposal by banking regulators to integrate portions of the Basel agreement into its final leverage ratio rule. The industry continues to suggest, however, that the rule should be amended so that it does not become the binding capital constraint on banks.

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