As we reported in our bulletin “More, More, More: A Summary of the Basel Proposals,”1 in December 2009, the Basel Committee on Banking Supervision (“BCBS”) published two consultative documents proposing significant reforms to the Basel II framework.2 These relate to, among other things, the definition of capital, the treatment of counterparty credit risk, the introduction of a leverage ratio and the imposition of global liquidity standards (the “December 2009 Proposal”).3

Following an extensive consultation process during which many concerns were raised as to the scope and effect of the December 2009 Proposal, including concerns that many banks and financial institutions may be unable to function with the increased capital and liquidity requirements (at least until there is a significant economic recovery), BCBS announced on 26 July 2010 that its oversight body had reached agreement on proposed capital and liquidity reforms. It also announced that it intended to finalise the calibration and phase-in arrangements for the reforms at a meeting in September 2010.