Banking Supervision Regulation - Comment Letter - Japanese Bankers Association - August 26, 2011
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Consultative Document: Globally systemically important banks: Assessment methodology and the additional loss absorbency requirement
August 26, 2011
From the comment letter:
- The JBA strongly supports setting multiple indicator-based measurements and bucketing approaches and implementing these in stages. The introduction of uniform surcharges with no regard to differences in individual banks’ risk profiles and other factors should be avoided.
- The JBA believes the risks caused by global systematically important banks (G-SIBs) can be alleviated not only by capital surcharges, but also by locally established frameworks such as deposit insurance or other bankruptcy resolution legal systems and lending limits. In accordance with the levels of various regulations and systems and characteristics of business models in different countries, qualitative assessments by local authorities should be seriously respected.