Today the Committee on Capital Markets Regulation submitted a statement responding to the recent proposal released by the FSB setting an international standard for the minimum quantity of loss-absorbing instruments that G-SIBs will be required to issue.  Our statement points out that the proposed minimum is unjustifiably large, was established with very little transparency, is unsupported by empirical evidence, and is unrelated to several measures of risk. The full text of the statement may be downloaded here