IIF-GFMA-ISDA joint NSFR letter to EBA Public Hearing

The IIF, GFMA, and ISDA jointly submitted the letter to the European Banking Authority (EBA), responding to its Public Hearing in October 2015 that relates to the implementation of the NSFR in Europe.'  The letter seeks to encourage the EBA to broaden the scope of its empirical review; to more carefully analyze product level impacts of the NSFR; to analyze the ability and willingness of NSFR-surplus banks to cover NSFR-deficit banks' withdrawal from capital markets; and its interaction with work on the Capital Markets Union; and to reconsider some of its assumptions in relation to bank funding models.