As discussed in Section 2.7, under CRD IV/CRR, banks will typically have twelve months to meet an increase in the CCB, although the legislation provides for a shorter implementation period in exceptional circumstances. A decision to decrease the CCB can take effect immediately. The FPC can make Recommendations to the PRA with regard to the permissible length of time for banks to comply with CCLB Directions. In the Leverage Ratio Review, the FPC proposed that, in some circumstances, it could recommend to the PRA to allow a period for banks to comply with increases in the CCLB of up to 24 months. The FPC could make such a Recommendation with respect to all banks, or a class of banks - for example, mutuals. In considering whether to make a Recommendation of a longer compliance period, the FPC would judge the potential benefits of this in relation to the potential costs.
The main potential benefit of requiring the CCLB to be met as quickly as the CCB is that banks would have to take measur
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