Date: September 19, 2014

Issue: Bank for International Settlements regarding NSFR

To: Bank for International Settlements

Filing Type: International

Description: The GRGI is concerned the proposed NSFR may dislocate the balance necessary to ensure appropriate capital formation and prudent risk management by businesses, thereby harming economic growth and job creation. We also wish to express our concern about the potential creation of inconsistent regulations across jurisdictions and further contribution to the opaqueness and confusion attributed to the overall complexity of current Basel III regulatory capital rules (“Basel III”).  

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