Basel Committee’s Consultative Document: Definition of Capital Disclosure Requirements

GFMA provides comments to the Secretariat of the Basel Committee on Banking Supervision (BCBS) in response to the Consultative Document: Definition of capital disclosure requirements, 19 December 2011.

GFMA believes the BCBS focus on post-2018 capital disclosures, taking more time to agree on the specific modalities of that disclosure, and not implement the transitional template. GFMA makes this suggestion for reasons including:

• The value of the transitional templates are compromised by the uneven pace of implementation of rules governing Basel III, as well as revisions to and uncertainties about risk-weighted asset calculations.
• It is difficult to evaluate the impact of this proposal without understanding the bigger picture of upcoming Pillar 3 revisions, as well as additional reporting and disclosure that will result from other international policy initiatives.
• This proposal, as with any other reporting and disclosure proposals, should be subject to a cost/benefit review. One step that clearly reduces costs and enhances benefits is to ensure data definitions are harmonized where possible, within and across templates.