ISDA/GFMA/IIF Global NSFR Briefing Note

ISDA, GFMA, and IIF welcome the decision by the Basel Committee on Banking Supervision (BCBS) in its review of the net stable funding ratio (NSFR) to give national jurisdictions the ability to lower the punitive 20% add-on for gross derivatives liabilities (GDL) to 5%. We believe the BCBS should adopt the 5% as a permanent measure, as this would reflect an appropriate compromise that would promote international consistency and avoid unintended consequences to derivatives businesses.

To the extent that the BCBS chooses to take no further action and jurisdictions move ahead with implementation of the NSFR, we believe they should do the same. Doing so would also free up resources within both the public and private sectors to focus on other critically important issues, ensure international consistency in the application of a framework and a level playing field for firms across jurisdictions, and avoid a potential increase systemic risk resulting from market fragmentation that would occur if different jurisdictions were subjected to different requirements.

Eyeing the Basel III Finish Line

An effective regulatory capital framework relies on multiple ingredients, from appropriate drafting to rigorous testing and consultation. Even minor calibration distortions can inflate capital requirements, which could negatively affect the capacity of banks to support deep and liquid markets, with...

Joint Comment Letter on Basel III Endgame Proposal

The Institute of International Finance (IIF), the International Swaps and Derivatives Association, Inc. (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) today submitted a joint comment letter to the Board of Governors of the Federal Reserve System, the...