Status: Draft -- Not PublishedWill be live at 03/18/2016 00:00
IIF/IBFed Response to the BCBS's Consultation Paper on 'step-in risk'
The industry is concerned about the Committee's proposal, its scope, and its potential implications for the ability of banks to engage in key financial activities, such as asset securitization and asset management. In the industry's view, this proposal lacks clarity, transparency and focus and ignores the fact that "step in" during the recent financial crisis was largely limited to singular events or certain investment structures. In light of that, the industry believes the framework is overly broad. Therefore, the industry asked the Committee not to proceed with its proposal. At the very least, the Committee should consider waiting for the various regulatory changes already in train to become fully effective before advancing further measures such as this proposed step-in risk framework.