The BSA is pleased to respond to the combined consultations on the Leverage Ratio (LR) framework. In this response - which is broadly supportive -we address both FPC and PRA proposals together in one document
The BSA and its members have consistently favoured robust and appropriate standards of financial stability, and of individual firm resilience. Our members account for nearly 20% of the cash savings market, and specialize in higher-value savings rather than transaction accounts. So general depositor confidence -promoted by vigorous and visible financial stability measures -remains of overriding importance to them. Our members also rely heavily on a resilient payments and clearing infrastructure provided mostly by systemic banks. And through the FSCS, our members are also continuously exposed to the costs of bank failure, if individual resilience proves insufficient. For all these reasons, therefore, the BSA needs no convincing of the imperatives for resilience and financial stability. But the framework and metrics must be appropriate.
Notwithstanding our historic objections to the leverage ratio, we are broadly content with the specific proposals from both FPC and PRA with the exception of the conversion factor for LR buffers,
Read the full response here.