The proposed definition of default and treatment of downturn LGDs (loss  BIS Review 18/2007  3  given default) are also areas that have received attention from commenters. Additionally, there has been some concern expressed about retention of the existing leverage ratio.
The U.S. agencies remain sensitive to these and other issues raised by commenters so far, including the overall burden and costs associated with the current proposals, as well as any potential competitive effects that may arise. Once we have received all comments on the proposals, we intend to review all comments carefully to assess what is the best way forward.