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TCH Comments on Basel Capital Disclosure Requirements

The Clearing House Association (TCH) and the Institute of International Finance (IIF) submitted a comment letter responding to the Basel Committee’s Consultative Document on the Definition of Capital Requirements. TCH and IIF generally support the use of common templates to achieve comparability in disclosures, but propose that banks have the option to make detailed information on capital available only on their websites rather than in their published financial reports. In addition, the associations recommend that the Committee delay the proposed 2013 implementation date of the new disclosures to provide sufficient lead time for the national implementation of capital disclosure requirements. Furthermore, the associations believe banks should provide narrative explanations of the most significant differences between the regulatory capital template instead of the balance sheet line-by-line mapping of the capital disclosure template and balance sheet.