ISLA has today responded to the European Commission’s consultation on the finalisation of Basel III. A copy of the full consultation can be found here.
Whilst the consultation covered a number of proposed changes, our focus has been on the proposed changes and application of Minimum Haircut floors.
The key message in our response is a need to clarify the scope of the minimum haircuts given their intended objectives, and to warn against making the application too complex that liquidity is driven from the market.
