EFAMA welcomes the FSB recommendation that jurisdictions develop domestic frameworks to monitor and mitigate the build-up of leverage. These analytical frameworks should take a holistic approach and be empirically driven. The main systemic risk stemming from leverage is the imbalance between liquidity demand and supply during periods of stress, not the (collective) default of non-bank financial intermediaries.

Rather than promoting new macroprudential interventions, such as activity-based or concentration-related measures, the FSB should prioritise international convergence in regulatory approaches, supervisory reporting, and oversight capabilities, as well as the development of an enabling regulatory regime (e.g., by facilitating the use of non-cash collateral and access to repo markets). A supervisory authority cannot properly calibrate its macroprudential interventions without these foundations.