The European Banking Federation (EBF) appreciates that the calibration of the standard is at the lower end of the spectrum as originally proposed by Financial Stability Board (FSB) members and allows for a phasing in by 2022. Given the cumulative effects of various capital buffers, the EBF  urges policy makers to carefully gauge the implementation of the standard to ensure that it is indeed calibrated at the right level, balancing financial stability with economic growth.
	It should be ensured that application of the Total Loss Absorbing Capacity (TLAC) for Globally Systemic Important Banks (GSIBs) requirement is correctly articulated so that it is consistent with the Minimum Requirement for Own Funds and Eligible Liabilities (MREL) introduced by the Banking Recovery and Resolution Directive (BRRD) which is applied to all banks in Europe.
	“TLAC is a logical development in capital adequacy, but it will need to fit with European bank resolution measures. We need regional calibration,” said Wim Mijs, Chief Executive of the EBF.“ If not done sensibly, the cumulative force of all these new proposals can seriously constrain EU bank lending and can harm Europe’s global competitiveness. By  the  way, TLAC addresses the very  same issues that  are  being  dealt  with  in  the EU  Bank  Structural  Reform proposal. It effectively makes the EU BSR proposal obsolete.”
	The final FSB  TLAC term sheet is to be confirmed by the G20  Meeting in Antalya, Turkey on 15-16 November.  The  EBF  is  keen  to  discuss  its  application  in  the  EU  in  a  way  to  preserve  the universal banking model to support jobs, markets and economic growth in Europe.
	Press release
      
      
      
      
        © EBF
     
      
      
      
      
      
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