The Committee evaluated the case for lowering the 20% CCF under the Basel II standardised and FIRB risk-based measures. The CCF is relevant for short-term self- liquidating trade letters of credit arising from the movement of goods. Essentially, it reduces capital requirements by 80% as compared to positions that are subject to a 100% CCF. The current 20% CCF has been part of the Basel capital framework since their inception in 1988. The CCF expresses the likelihood of an off-balance sheet position to become on- balance sheet, ie it is not related to the riskiness of a counterparty which is expressed.
