The ABA lodged its submission with the BCBS on the Consultative Document Reducing variation in credit risk-weighted assets - constraints on the use of internal model approaches. The ABA supports a simple and comparable capital framework that retains appropriate risk sensitivity.
The ABA provided the BCBS with comments on the Consultative Document: Pillar 3 disclosure requirements - consolidated and enhanced framework. The ABA is supportive of the proposed enhancements and the consolidation of all existing and prospective BCBS disclosure requirements into the Pillar 3 framework.
The ABA responded to the BCBS CD: Standardised Measurement Approach for operational risk and in responding to the specific questions raised, also provided the Committee with additional feedback for consideration.
The ABA provided APRA with its comments on the Discussion Paper: Margining and risk mitigation for non-centrally cleared derivatives. While generally supporting the comprehensive submissions by the Australian Financial Markets Association and International Swaps and Derivatives Association, the ABA and members have some specific comments on CPS 226 which are of particular importance to members.