Due to the publication of Finalising post crisis reforms by the Basel Committee on Banking Supervision, CCP12 would like to highlight its continued concerns regarding the application of the Leverage Ratio on CCP cleared client business. CCP 12 is the Global Association of Central Counterparties composed of 35 major central counterparty (CCP) organizations in EMEA, Asia-Pacific and the Americas.
CCP12 especially emphasizes the importance of allowing banks to offset segregated margin on behalf of clients against their client trades for purposes of calculating leverage ratio exposures, and further acknowledge that clearing members who meet the appropriate accounting criteria for segregation should also be able to remove cash posted as margin from their own balance sheet calculations for the purpose of determining the leverage ratio.