The strict application of the Basel 4 capital requirements, as proposed by the Dutch Ministry of Finance and Dutch Central Bank (DNB) earlier this week, would limit the capacity for economic recovery. 
      
    
    
      Banks would be required to increase 
their buffers further while simultaneously meeting the societal 
expectation to finance the restarting of business activity in the 
Netherlands. This approach strongly contrasts with the supervisors’ 
reaction to the COVID-crisis, which gave flexibility to continue 
providing ample credit to companies affected by the lockdowns. The Dutch
 Ministry of Finance and the Dutch Central Bank (DNB) have repeatedly 
stated that Dutch banks are well capitalised. Now that we are at the 
start of the economic recovery and entering a period that will require 
significant investments, this policy position is not very helpful. 
Furthermore, it hampers the necessary financing of the sustainable and 
digital transformation to which banks would like to contribute. From 
this perspective, a more proportionate implementation of Basel 4 would 
be desirable.
he strict application of 
the Basel 4 capital requirements, as proposed by the Dutch Ministry of 
Finance and Dutch Central Bank (DNB) earlier this week, would limit the 
capacity for economic recovery. Banks would be required to increase 
their buffers further while simultaneously meeting the societal 
expectation to finance the restarting of business activity in the 
Netherlands. This approach strongly contrasts with the supervisors’ 
reaction to the COVID-crisis, which gave flexibility to continue 
providing ample credit to companies affected by the lockdowns. The Dutch
 Ministry of Finance and the Dutch Central Bank (DNB) have repeatedly 
stated that Dutch banks are well capitalised. Now that we are at the 
start of the economic recovery and entering a period that will require 
significant investments, this policy position is not very helpful. 
Furthermore, it hampers the necessary financing of the sustainable and 
digital transformation to which banks would like to contribute. From 
this perspective, a more proportionate implementation of Basel 4 would 
be desirable.
Dutch Banking Federation
      
      
      
      
        © NVB
     
      
      
      
      
      
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