Comments & Position Papers


WOCCU Comment Letter to IADI on Public Policy Objectives for Deposit Insurance Systems

World Council supports the Association of Deposit Insurers’ (“IADI”) principal public policy objectives which state that the essential objectives are to protect depositors and contribute to financial stability.


WOCCU Basel Committee Consolidated Framework Comment Letter - July 2019

WOCCU urges Basel Committee to provide clearer instructions to national-level authorities who continue to apply Basel Standards without regards for proportional tailoring to the risk or complexity of credit unions or other community-based mutal depository institutions.

A copy of the comment letter can be viewed here.


Consultative Document: Revisions to Leverage Ratio Requirements

World Council urges Basel Committee to make the use of daily averages in leverage ratio disclosures optional for credit unions.

A copy of the comment letter can be viewed here.


WOCCU Urges Preservation of Community-based Financial Institutions' Access to Interest-Rate Derivatives

WOCCU urged the Basel Committee to finalize a revision to the leverage ratio treatment of client cleared derivatives that helps preserve community-based financial institutions’ access to interest-rate derivatives in order to hedge interest rate risk.

WOCCU believes a standardised approach to counterparty credit risk (SA-CCR) should be used for banks’ leverage ratio capital requirements with respect to client cleared derivatives.

A copy of the comment letter can be viewed here.



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Comments on the Draft Guidance for Private Sector Information Sharing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.

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.


Financial Stability Board

WOCCU: Financial Regulatory Reforms Should Spur, not Limit SME Financing

The World Council of Credit Unions told FSB in March it's abundantly clear that the financial regulatory reforms adopted in response to the financial crisis during the 2007-2009 timeframe resulted in a more robust and complex regulatory framework. The additional complexity often filters down disproportionately to smaller, less-complex institutions such as credit unions and other community based cooperative institutions. 

(2019-Mar. 18)

International Association of Deposit Insurers

IADI Urged to Consider Credit Union Deposit Insurance Schemes in Setting Ratios

World Council of Credit Unions (World Council) filed its comment letter on the International Association of Deposit Insurers on the Association’s draft research paper Deposit Insurance Fund Target Ratios.  WOCCU included information on the National Credit Union Share Insurance Fund (NCUSIF) in the United States, the United Kingdoms’ Financial Services Compensation Scheme (FSCS), and Canadian provincial deposit insurance funds noting that including these successful approaches taken by the respective schemes, albeit different in their approaches, can help inform the IADI’s future work on deposit insurance fund target ratios.  

The letter notes that these funding structures strike an appropriate balance vis-à-vis the costs of levies versus pro- and counter-cyclality versus maintaining readily available funds to pay for insurance losses.

(2018-Mar 16)

National Credit Union Administration

Advance Notice of Proposed Rulemaking for Supplemental Capital

World Council comments to NCUA regarding Rulemaking for Supplemental Capital.


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)