The European Banking Federation has welcomed the Basel Committee on Banking Supervision (BCBS) proposals to revise the supervisory framework for measuring and controlling large exposures on proven methods under the existing capital and large exposures regimes. The EBF fully supports the efforts of the BCBS to re-use existing exposure measures as much as possible, and would recommend applying the same exposure for the Large Exposure Regime (LER) as for Pillar I purposes everywhere, including for off-balance sheet items. However, it states that the Committee's preference for a simple method of calculating exposures is not justified. The EBF believes that this would lead to a diversion between the capital and large exposure regimes. Banks should be able to apply the same methods for both purposes and should continue to have the option of using more sophisticated methods, ie internal models, to determine exposure values. The EBF has also published comments on the Consultation Paper on Asset Encumbrance.