GFMA comments on Basel Committee’s capital surcharge proposal

26 August 2011

The Global Financial Markets Association (GFMA) announced it has submitted comments to the Basel Committee on Banking Supervision in response to the Consultative Document: 'Global systemically important banks: Assessment methodology and the additional loss absorbency requirement'.

While GFMA strongly supports the goal of the Basel Committee to promote financial stability, it has serious concerns with the proposed surcharge and believes the proposal should be fundamentally revised and re-proposed to address these concerns.

GFMA outlined the following fundamental concerns:

• Benefits of surcharge are not demonstrated to exceed costs of reduced economic growth. GFMA believes the Consultative Document does not demonstrate that the marginal safety benefits of the capital surcharge offset the cost in reduced economic growth. GFMA therefore renews its request that the comment period be extended until after the Committee’s cost-benefit analysis has been made public so that all parties can appropriately review and comment on that analysis.
• The amount of the proposed surcharge is not justified. The very summary analysis provided to support the amount of the surcharge – based primarily on the so-called “expected impact approach” – includes little empirical support, and lacks transparency. It does not support a surcharge, especially of the magnitude proposed.
• The “cliff effect” of the proposed surcharge is also not justified and should be adjusted. As proposed, any reduction in a G-SIB’s capital below the extra amount required by the proposed buffer would result in immediate and substantial restrictions on capital distributions. GFMA suggests an alternative approach.
• There should be clear and well defined offsets for improvements in orderly resolution regimes. The establishment of orderly resolution regimes for G-SIBs should expressly be included as a mitigating factor in determining the amount of the capital surcharge.
• The lack of transparency in the test methodology undercuts its usefulness both to G-SIBs to reduce risk and to markets to monitor risk-taking. A G-SIB would be unable to calculate its surcharge amount, and therefore could not effectively calibrate the amount by which changes in its conduct would decrease its surcharge amount. In addition, without additional transparency, markets would be less able to discipline G-SIBs for the amount of systemic risk they choose to take.
• Clear problems with the indicator-based measurement approach should be addressed. Problems include the likely correlation between criteria, such as the over-counting of “size”; the distortions created by grading G-SIBs based only on relative scores; the failure to take into account diversification benefits; and the inclusion of factors in the “substitutability” indicator that are not clear proxies for systemic risk.
• Going concern contingent capital should be allowed as part of the surcharge. These instruments absorb loss in the scenarios that are relevant for the safety of G-SIBs, and are recognised as high-quality capital for both national regimes and for Tier 1 capital.

GFMA's full comment letter

BCBS Consultative Document 

Full article

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