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Summary: HSBC North America Holdings, Inc. supports the proposed revisions to the capital framework, particularly the emphasis on aligning requirements with economic risk and reducing complexity. The bank recommends specific refinements, including more risk-sensitive weights for high-quality corporate exposures, adjustments to the CVA applicability threshold, and the removal of the Default Risk Charge for term repo-style transactions.
HSBC North America Holdings, Inc., on behalf of itself and its subsidiaries (collectively, “HSBC”) provides the following comments related to the proposed regulatory capital rule.