Page 17 - 期货和衍生品行业监管动态（2025年2月刊）

期货和衍生品行业监管动态

The Basel III capital framework was designed to strengthen the regulation,

supervision and risk management of banks in response to weaknesses exposed by the

global financial crisis. As the last components of the framework are finalized and

implemented around the world, it is critical that this quest for stability in the banking

sector is balanced with the need to maintain deep and liquid financial markets. If

capital requirements are disproportionately punitive, this will compromise the

liquidity and smooth functioning of markets, which will negatively affect economic

growth.

It has long been clear that the Basel III ‘endgame’ package of proposed rules,

which US regulators published for consultation in 2023, is inappropriately calibrated

and would constrain the capacity of banks to offer vital intermediation and risk

management services. If the rules are not comprehensively revised, this would have

grave consequences for hundreds of thousands of companies that rely on banks to

raise financing for growth and investment. From diminished access to funding to a

lack of hedging solutions and increased vulnerability to external shocks, it is

companies that will suffer the consequences.

That’s why ISDA stands firmly by the recommendations we made to US

regulators last year, which were based on the results of a quantitative impact
assessment. Those recommendations, which include greater recognition of

diversification in the market risk framework to reflect actual risk exposure and

changes to certain aspects of the rules for credit valuation adjustment and securities

financing transactions, would improve the risk sensitivity of the Basel III endgame

and avoid negative repercussions for US capital markets.

It is also vital that regulators take a holistic view of how different rules interact

with each other. Capital requirements must not be implemented in a vacuum, without

due consideration of how they might affect other regulations and market processes.

Central clearing, widely recognized to be a vital risk-reducing activity, is a good

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