JSDA's Comments on the consultative proposal on Countercyclical capital buffer issued by the BCBS

In December 2009, the Basel Committee on Banking Supervision (BCBS) issued consultative proposals for "Strengthening the resilience of the banking sector" and "International framework for liquidity risk measurement, standards and monitoring", which cover the following key areas:

- raising the quality, consistency and transparency of the capital base,

- strengthening the risk coverage of the capital framework,

- introducing a leverage ratio,

- introducing a global minimum liquidity standard, and

- introducing a series of measures to promote the build-up of capital buffers in good times that can be drawn upon in periods of stress, etc.

Following the proposals mentioned above, the BCBS issued consultative proposal on "Countercyclical capital buffer" in July 2010. Since this proposal have a major impact on the financial and capital markets and on the economy overall while mainly aiming at "protecting the banking sector", JSDA provided the BCBS with its views on the proposal from the perspective of the Japanese securities industry consulting with the International Advisory Committee and others.

JSDA Letter to BCBS

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