Comments & Position Papers

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Basel Committee on Banking Supervision

Consultative Document: Simplified alternative to the standardised approach to market risk capital requirements

WOCCU Urges Revisions to Basel proposal on Simplified Alternative to Market Risk Capital Requirements.
(2017-Sept-27)

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WOCCU Urges Changes to Proposed Rules on Short-term Securitisations

The World Council of Credit Unions filed two comment letters urging changes to benefit credit unions on the Basel Committee on Banking Supervision(Committee) Consultative Documents on the Criteria and Capital treatment for simple, transparent and comparable  short-term securtisations.

A copy of the letters can be viewed here for the Criteria, and here for the Capital Treatment.

(2017-October-5)

WOCCU Urges Revisions to Basel Simplified Alternative to Market Risk Capital Proposal

WOCCU urged several revisions to the Basel Committee on Banking Supervision’s consultative document Simplified alternative to the standardised approach to market risk capital requirements.

A copy of the comment letter can be viewed here.

(2017-September-28)

Revisions to the Annex on Correspondent Banking

World Council supports the Basel Committee’s efforts to update its correspondent banking guidance to help address “de-risking” and incorporate the Financial Action Task Force’s recently updated interpretive note on correspondent banking anti-money laundering/countering the financing of terrorism (AML/CFT) standards.

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(2017-Feb-23)

Prudential Treatment of Problems Assets

World Council supports:

  1. Uniform Definition for “Non-Performing Exposures”
  2. The Committee Should Redefine “Default” to Eliminate the Less Stringent
    Treatment Currently Accorded to IRB Institutions 
  3. Retail Exposures Should Be Analyzed on a Transaction by Transaction Basis
  4. Criteria for Exit from the Forborne Exposures Category
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(2016-July-15)

Standardised Measurement Approach for Operational Risk

World Council provides a Consultative Document to Basel Committee on Banking Supervision regarding their Standardised Measurement Approach for Operational Risk

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(2016-May 28)

Revisions to the Basel III Leverage Ratio Framework

World Council provides a Consultative Document to Basel Committee on Banking Supervision regarding their Reducing variation in credit risk-weighted assets – constraints on the use of internal model approaches

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(2016-June 23)

 

Financial Action Task Force (FATF):

Comments on the Draft Guidance for Private Sector Information Sharing

WOCCU urged FATF to make numerous changes to ease the burden on credit unions and to streamline the AML/CFT framework surrounding information sharing.
VIEW
(2017-July-31)

International Accounting Standards Board (IASB)

IFRS 9 Loan Loss Accounting for Cooperative Financial Institutions

World Council comments to IASB regarding their International Financial Reporting Standard (IFRS) 9 Financial Instruments
VIEW
(2016-12-19)

 


Global Partnerships for Financial Inclusion

Global Standard Setting Bodies and Financial Inclusion

World Council comments to GPFI regarding their Global Standard-Setting Bodies and Financial Inclusion: The Evolving Landscape
VIEW
(2016-Jan 29)

U.S. Internal Revenue Service

World Council and CUNA jointly support S. 869 and H.R. 2054

which repeals burdensome requirements created by the Foreign Account Tax Compliance Act (FATCA)
Letter to Representative Mark Meadows
Letter to Senator Rand Paul
(2014-July 18)

Residence Based Taxation and the Foreign Account Tax Compliance Act (FATCA)

Credit Union National Association and World Council endorse Foreign Account Tax Compliance Act (FATCA)
VIEW
(2014-July 18)

Proposed Regulation to Implement the Foreign Account Tax Compliance Act (FATCA)

World Council comments on the US IRS notice of proposed rulemaking to implement the Foreign Account Tax Compliance Act (FATCA)
VIEW
(2012-April 30)

Financial Stability Board

Adequacy of loss-absorbing capacity of global systemically important banks in resolution

World Council comments to the Financial Stabilty Board regarding their Adequacy of loss-absorbing capacity of global systemically important banks in resolution consultative document
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(2015-Feb 2)

National Credit Union Administration

Advance Notice of Proposed Rulemaking for Supplemental Capital

World Council comments to NCUA regarding Rulemaking for Supplemental Capital.

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