Dear Secretariat,
The Global Financial Markets Association (GFMA)1 welcomes the opportunity to comment on the consultative document; Definition of capital disclosure requirements, 19 December 2011. GFMA would like to express its support for the work that the Basel Committee has undertaken to implement clear and comparable disclosure of regulatory capital following the implementation of Basel III, which entails a substantial redefinition of capital. As pointed out in the consultative document, at present, there is no consistent format across all jurisdictions for disclosure of the composition of capital. Moreover, as Basel III introduces significantly more precision in the definition of eligible capital it is appropriate to revisit the existing Pillar 3 disclosure requirements.
