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August 20 , 2009

Understanding Basel III, What is Different After November 2013


What is Basel III super-equivalent?

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Life is becoming more complex for risk managers. We must have a "forward-looking perspective", remember?We have all these new laws and regulations ...... but we also have rules, proposals and reports to consider.Have you ever discovered the common elements of the various initiatives, including the Volcker rule in the United…

Using Basel III as an excuse and imposing requirements beyond what is required by Basel III (like stricter interpretations, national options and discretions, and front-running).

We also call it "gold plating".

What Governor Daniel K. Tarullo said:

"The proposed LCR we review today is "super-equivalent" to the Basel Committee's LCR standard.

That is, the proposal is more stringent in a few areas, such as the transition timeline, the definition of high-quality liquid assets, and the treatment of maturity mismatch within the LCR's 30-day window."


Question: What is a "national discretion?

A good example is the Basel III Liquidity Coverage Ratio (LCR).

How many LCRs do we have in the Basel III papers?

Just one.

How many LCRs do we have in the Basel III US super-equivalence?

To the moment, just three!

According to Governor Daniel K. Tarullo:

"The proposed LCR is tailored to the systemic footprint of different U.S. banking firms.

Bank holding companies with less than $50 billion of assets—below the Dodd-Frank Act's enhanced prudential standards line—will not be covered by the proposal.
Bank holding companies that have $250 billion or more of assets or have substantial international operations will be subject to the full LCR proposal.

Firms in the middle range will be subject to a less stringent version of the LCR.

This tailored approach is consistent both with good public policy and with the gradation requirements in section 165."


At least, there is some consistency. The objective of the LCR is to promote the short-term resilience of the liquidity risk profile of banks. It does this by ensuring that banks have an adequate stock of unencumbered high-quality liquid assets (HQLA) that can be converted easily and immediately in private markets into cash to meet their liquidity needs for a 30 calendar day liquidity stress scenario.

Oops... sorry... not exactly...

According to Governor Daniel K. Tarullo: "The Board also is proposing on its own a modified liquidity coverage ratio standard that is based on a 21- calendar day stress scenario rather than a 30-calendar day stress scenario for bank holding companies and savings and loan holding companies without significant insurance or commercial operations that, in each case, have $50 billion or more in total consolidated assets."

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