Response to consultation on methodology for global systemically important institutions

Go back

(Question relating to the draft RTS) Are the timelines for the identification process and the coming into force of the buffer requirement adequate, and do they allow for sufficient time for adjusting to it?

We are satisfied that the timelines are adequate.

(Question relating to the draft Guidelines) Are the template and the instructions clear and sufficiently comprehensive for enabling institutions to complete the disclosure process?

Yes, but we need further clarity on leverage exposures, as detailed above.

(Question relating to the impact assessment) Do you agree with our analysis of the impact of the proposals in this CP? If not, can you provide any evidence or data that would explain why you disagree or might further inform our analysis of the likely impacts of the proposals?

We are satisfied with the analysis in the CP.

Name of organisation

British Bankers' Association