The second, lower level of regulation would come under a system governed by the Securities Commission and trustees. The two models proposed are:
These requirements would include a minimum level of capital, a minimum capital adequacy ratio, a minimum credit rating, a limit on related party exposures, and some governance and disclosure requirements.
Tier Two Deposit Takers (Enhanced Trustee Model)
These entities would face enhanced disclosure requirements and would be supervised by trustees and the Securities Commission.
It is proposed that they also meet other requirements such as a minimum capital requirement, possibly a mandatory credit rating, enhanced disclosure, capital adequacy measurement framework, more fit and proper person requirements. Importantly they would be required to disclose prominently that they are not an ADT.
It also points out that because a finance companies lends money to a range of borrowers “there is a potentially substantial level of contagion risk with deposit takers, both because of their funding nature and because they tend to be viewed as like entities.”
It also says that these deposit taking firms tend to be relatively highly geared compared to other forms of debt issues.
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