The NSFR is inappropriate for the capital markets industry at at this time and should be postponed pending further analysis of the impacts of the Liquidity Coverage Ratio, the Leverage Ratio, money market reforms, MiFID II, Brexit and other major regulations and events. The NSFR rules will have substantially negative implications for capital markets, some of which directly targets securities finance, and are an example of aiming for a gold standard of risk management while disregarding the damaging outcomes that such regulation would entail.
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