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View All Comment Letters and Position Papers

Pending Comment Letters

Your comments are extremely important to us to provide the best response by WOCCU to these regulatory proposals.

Listed below are all pending regulatory actions for which WOCCU intends to submit a Comment Letter. The listed date is the date by which Comments are due to the respective agency.  All Comment Letters filed by WOCCU can be viewed on the Comments & Position Papers tab. Comments filed by the European Network of Credit Unions can be found here.

Please be sure to provide us with your comments in advance of the Due Date so that we may include them in our Comment Letter.


Agency Pending Comment Letters Due Date
FATF
Public Consultation Recommendation 16 on Payment Transparency May 3, 2024
 

Recent News on our Competent Authorities

 

2024-03-21

Basel Committee Announces Core Principles Revision and Other Updates

The Basel Committee on Banking Supervision (the Committee) recently met to discuss key items impacting the financial service markets.

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Basel Committee Announces Core Principles Revision and Other Updates

2024-02-15

Comment Letter on Digital Fraud and Banking

In response to the Basel Committee on Banking Supervision's discussion paper regarding digital fraud, World Council submitted a comment letter on behalf of the global credit union movement. The Committee's discussion paper requested comments a description of fraud and the transmission channel's into the banking system. It also requested comments on whether there are additional banking initiatives related to digital fraud that should be pursued by the Committee. 

Among suggestions for a more inclusive description of digital fraud impacting credit unions, World Council urged the Committee to explore the methods and ramifications in which the most vulnerable populations are targeted. Digital fraud is another challenge credit unions face in their mission for financial inclusion. World Council requested the Committee consider additional education initiatives related to fraud activity and resources.

Click here to read the comment letter submitted by World Council.  

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Comment Letter on Digital Fraud and Banking

2024-01-31

World Council Submits Comment Letter on Disclosure of Cryptoasset Exposure

World Council has submitted a comment letter on the Basel Committee's public consultation Disclosure of Cryptoasset Exposure. The consultative document proposes a standardized disclosure template that would be required for financial institutions, including credit unions, with cryptoasset exposure beginning in January 2025. The Committee proposed the templates to ensure market discipline and better transparency on risks associated with exposure.  

Similar to other areas of the Basel Framework, World Council requested that proportionality or a more streamlined ability to disclose also be included in the requirements and standard templates. If credit unions decide to explore or take-on cryptoasset exposure in the future it is important that the reporting requirements for community-based financial institutions not be overly burdensome to ensure they are not excluded from new opportunities. 

Click here to read World Council's comment letter.  

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World Council Submits Comment Letter on Disclosure of Cryptoasset Exposure

2023-11-29

Basel Committee Consults on Disclosures for Climate-related Financial Risk

The Basel Committee on Banking Supervision issued a public consultation paper on a Pillar 3 disclosure framework for climate-related financial risks.

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Basel Committee Consults on Disclosures for Climate-related Financial Risk

2023-11-29

Basel Committee Provides Details on Climate-Related Financial Risk Management

In a recent newsletter the Basel Committee provided additional information regarding the status of implementation of the Principles for the effective management and supervision of climate-related financial risks (Principles) and current gaps.

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Basel Committee Provides Details on Climate-Related Financial Risk Management

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