The IIF is pleased to provide some specific requests for clarification on particular items in the final Basel III reforms that were announced on December 7, 2017. With the industry having now had the opportunity to undertake a detailed review of the final package, we have established a number of items that could be enhanced with further guidance and clarification.

Such clarifications will assist banks' preparations for implementation, as well as enabling impacts to be accurately tested and assessed. The IIF encourages the Basel Committee to address these both (i) via the publication of a Frequently Asked Questions (FAQ) document, and (ii) in the guidance and instructions for the upcoming Monitoring QIS exercise.

The IIF continues to supporting enhancements to the international capital framework, and we hope these areas for clarification can be a helpful step towards the upcoming implementation journey.