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TCH Submits Recommendations That Would Improve Basel’s Framework for Measuring and Controlling Large Exposures

The Clearing House Association, along with ABA, GFMA, FSR, ISDA and SFIG, submitted a comment letter to the Basel Committee on its recent Consultative Document proposing a supervisory framework for measuring and controlling large exposures to any single bank counterparty or group of connected counterparties. The Associations express support for the Basel Committee’s goal of establishing a framework for international consistency in large exposure standards and its decision to study the results of its quantitative impact study before reaching a conclusion on the final value of the large exposure limit. However, the Associations have fundamental concerns with certain aspects of the proposed framework. In particular: (i) in a number of areas, the framework’s proposed exposure measurement methods are not sufficiently risk sensitive and would substantially overstate actual economic risk; (ii) aspects of the framework are unnecessarily complex and appear to be driven by disparate policy goals, and (iii) the framework could restrict the ability of institutions to engage in important risk-management activities and, accordingly, adversely affect the costs and availability of many types of financial products and services provided to consumers, businesses, public sector entities, and institutional investors.