IBFed letter to BCBS on capital treatment of SFTs_11jan19

The IBFed appreciates the Basel Committee on Banking Supervision (BCBS) efforts to revise the Basel 3 standards.  The International Banking Federation (IBFed) has submitted numerous letters to the BCBS discussing various Basel 3 revisions and making recommendations for practical, and objective-focused ways those standards can be adopted. We anticipate that as domestic jurisdictions begin adopting the latest round of finalized standards, issues that were not previously anticipated or fully appreciated will present themselves. This letter addresses one of these specific issues, the minimum haircut floors for Securities Financing Transactions (SFTs), about which we have not previously commented.