The Associations support the Committee’s efforts to impose a leverage ratio as a supplementary backstop measure to the risk-based measure and we appreciate this opportunity to provide feedback on the final leverage ratio framework in the form of frequently asked questions (FAQs). These FAQs deal with aspects of the proposals that have been raised with the Associations over the past two months and highlight the need for clarification of a number of material interpretation issues in the new rules. We believe that it is important for the BCBS to clarify how the rules should be interpreted at this stage especially to ensure that they are transposed correctly and consistently in national and regional implementation measures, without unintentional adverse impacts on the markets.
