-According to this
position paper the proposed Capital Accord leaves next to improvements of the second consultative paper of the Basel Committee on Banking Supervision important questions still open. The credit risk model on which calibration is based is unclear. This goes particularly for the ultimate size of future capital requirements. Given the complexity of the new Consultative Document, the 31 May 2001 deadline set by the Basel Committee for comments should, in our view, not terminate the consultation. On the contrary, the
ESBG calls for the consultation process to be continued in the form of an open dialogue on these points even after the official deadline for comment has expired and – where necessary – even after adoption of the New Capital Accord. We feel that the credit sector industry should be given ample opportunity to provide its opinions during an ongoing and interactive consultative process. At the same time, the transitional period between the publication and the entry into force of the new Basel Capital Accord should not be extended.
© European Savings Banks Group
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