Comment on the Basel Committee’s Consultative Documents: “Strengthening the resilience of the banking sector,” and “International framework for liquidity risk measurement, standards and monitoring”(Exective Summary) [62 KB]
We, Japanese Bankers Association, are pleased to announce that today we have submitted our comments with regard to the Consultative Documents: “Strengthening the resilience of the banking sector” and “International framework for liquidity risk measurement, standards and monitoring” released by the Basel Committee on Banking Supervision.
We understand that the proposals in the Consultative Documents are part of the Committee's comprehensive response to the lessons of the financial crisis which relates to regulation, supervision and risk management of global banks.
However, we believe that an appropriate consideration is required to introduce the proposed rules from views of macro-economic impact on the market and real economies, balance between uniform regulations and national regulations, diversity of business models, phased-in implementation and grandfathering measures, and appropriate consultation procedures.
We are closely monitoring the development over the comprehensive quantitative impact study currently being conducted by the Committee. Going forward, we would like to express our views in a proactive way with regard to international financial regulation and supervision.
