I have sent a letter to OSFI commenting on their Draft Advisory, which proposes to allow cumulative in-kind coupons on Innovative Tier 1 Capital.
This letter reflects information previously mentioned on PrefBlog:
- OSFI Drafts Advisory to Create New Tier 1 Capital
- Cumulative Tier 1 Interest?
- NBC Asset Trust issues Asset-Based Tier 1 Paper
It also builds on the comments made in:
[…] has been noted, OSFI has no equivalent guidelines, which has led to public confusion over OSFI’s regulatory […]
[…] have made OSFI aware of my views on this […]
[…] have not yet reviewed the intricacies of the advisories, but it appears that the the draft advisory I thought was so appalling has been adopted in toto. Canadians can be, er, proud to declare that we are basically the only […]