meme le core tier 1 et le common tier 1 ne sont pas toujours definis de la meme maniere par les banques. bis central bankers ’ speeches levier des principales banques europeennes levier des principales banques americaines source : rapports financiers des banques ( calculs banque de france - semasfi ) 2. impact de la non compensation ( netting ) des operations sur les derives sur le total bilan et les leviers des banques us augmentation du total bilan si non compensation des operations sur derives ( hors repos ) impact du netting sur les ratios de levier des banques source : risk. net ( d ’ apres credit suisse et fitch ) bis central bankers ’ speeches

carefully assessed in order to obtain a fair reciprocal treatment. the basic principle is fairly simple : a third country trade repository or clearing house could service participants or markets of other countries provided that the legal and supervisory arrangements are deemed equivalent and that international cooperation arrangements are established. but equivalence is not really easy to assess and one could understand a more conservative approach based on a systematic registration. indeed, under such a regime, a third country trade repository or clearing house servicing participants or markets of another country would have to be registered by the competent authorities of that country and, once registered, would have to be subject to regulations and to on - site inspections, in addition to the domestic ones. while, in order to decrease the risk of burdensome and inefficient regulatory overlap, the position held in the european emir regulation proposal is to support mutual recognition regimes, registration regimes do remain implemented in other major jurisdictions ; in particular, in the us as foreseen in the dodd frank act that applies to activities outside the us that have a “ direct and significant connection with activities in, or effect on, commerce of the united states. ” in practice this may mean that non - us entities would become subject to the requirement of the dfa, unless an exemption is granted. in my view, the us regulation and the subsequent registration to us authorities should not lead european entities to be subject to a redundant or a double regulation. the issue of access to the information stored in trade repositories is also particularly sensitive. one can easily understand that if the national supervisory bodies keep both full access to the locally registered tr and full control of the access granted to foreign supervisors, we will rapidly conclude that we need one tr per asset class and per country, which will clearly be sub - optimal from a supervisory point of view, since we need a consolidation of the risks, and from an industrial point of view with an increased cost for everybody. hence, it is crucial to continue our common discussions with the american authorities in order to limit redundancies and inconsistencies, of information decrease the risks of regulatory arbitrage or overlaps, whilst our common objective remains the safety and soundness of financial market infrastructures. constructive dialogue between rule making agencies is essential. 2. 2 in the field of regulatory and accounting standards, i would like to point out that convergence is highly needed in order to allow users of financial reporting, especially regulators, analysts, and market participants to draw relevant comparisons between banks. – firstly,