On September 20, the Global Financial Markets Association (GFMA), American Bankers Association, Financial Services Roundtable, Institute of International Bankers, Institute of International Finance (IIF) and the International Swaps and Derivatives Association (collectively, the Associations) responded to the June 2013 Consultative Document "Revised Basel III leverage ratio framework and disclosure requirements (Proposed Framework)" issued by the Basel Committee on Banking Supervision (BCBS) of the Bank for International Settlements (BIS).