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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
Financial Stability Board Addressing the Regulatory, Supervisory and Oversight Challenges Raised by "Global Stablecoin" Arrangements July 15, 2020
European Commission Consultation on the Renewed Sustainable Finance Strategy July 15, 2020
European Commission Money Laundering & Terrorism Financing - Action Plan July 29, 2020
Basel Committee on Banking Supervision Capital Treatment of Securitisations of Non-performing Loans August 23, 2020
Financial Action Task Force Amendments to Recommendation 1 and its Interpretive Note August 31, 2020
European Commission Review of Consumer Credit Directive September 1, 2020
European Banking Authority EBA Calls for Input to Understand Impact of De-risking on Financial Institutions and Customers September 11, 2020
IFRS Exposure Draft and Comment Letters: General Presentation and Disclosures (Primary Financial Statements) September 30, 2020
Financial Stability Board Too-Big-To-Fail Reforms Made Banks More Resilient and Resolvable, but Gaps Need to Be Addressed September 30, 2020
European Commission Consumer credit agreements – review of EU rules, New Consumer Agenda October 6, 2020
International Accounting Standards Board  Comprehensive Review of the IFRS for SMEs
Standard

October 27, 2020
IFRS Business Combinations--Disclosures, Goodwill and Impairment December 31, 2020
 

ENCU Responds to European Commission's Initiative to Combat AML/CFT

The European Network of Credit Unions (ENCU) responded to a request for feedback on the European Commission’s (Commission) action plan on money laundering & terrorism financing. According to the Commission, “Recent money laundering scandals put pressure on the EU to have a close look at the adequacy of the EU anti-money laundering framework.”[1] This initiative by the Commission aims to address areas of needed improvement in the money laundering and terrorism finance EU framework through new proposals. ENCU responded to this request for feedback and emphasized its support for this initiative while urging the Commission to consider “a risk-based approach, proportional requirements, national-level discretion to tailor regulations, and clear guidance to national level regulators on how to apply proportional regulations so that credit unions can continue its mission to improve financial inclusion and provide affordable and necessary services to the underserved European Union community.” ENCU’s comment letter to the Commission can be found here.

[1] See, Roadmap, Context, available at here.

(2020-March-11)

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World Council Urges Basel Committee to Consider Credit Union Difference

The Basel Committee on Banking Supervision (Basel Committee) released a consultation requesting feedback on their Consultative Document: Introduction of Guidelines on Interaction and Cooperation Between Prudential and AML/CFT Supervision (Consultative Document). The Basel Committee’s goal is “[t[o] enhance the effectiveness of supervision on banks’ ML/FT risk management, the Committee proposes to provide further guidelines on interaction and cooperation between prudential supervision and anti-money laundering and countering financing of terrorism (AML/CFT) supervision.” World Council supported this objective, but urged the Basel Committee to not only consider the unique structure of credit unions when determining how to assess an institution’s money laundering and financing terrorism risks, but to give clear guidance to national-level regulators on how to appropriately and proportionately assess risk for credit unions. World Council further suggested that both prudential and AML/CFT supervisors outline a coordinated proportional approach to the enforcement, management, and assessment of credit unions based on their unique organization structure, as well as consideration for privacy concerns surrounding information sharing with supervisors and confidentiality concerns with observers that may participate in colleges or other attendees participating on an ad hoc basis. WOCCU’s response to the Consultative Document can be found here.

(2020-February-6)

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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.
(2017-July-31)View

International Accounting Standards Board (IASB)

WOCCU Gives Input on Whether Cooperative Shares are Considered Equity or Liabilities

World Council comments to IASB regarding their discussion paper - Financial Instruments with Characteristics of Equity.
(2019-Jan-7)

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Financial Stability Board


WOCCU FSB Comments on Too Big To Fail Reforms

(2019-June. 21)

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National Credit Union Administration

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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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
(2016-Jan 29)View