Comments & Position Papers


Basel Committee on Banking Supervision

Consultative Document: Pillar 3 Disclosure Requirements - Updated Framework

Proportionality Urged by WOCCU in Basel Pillar 3 Updated Disclosures so as to not subject less complex institutions witha lower risk profile to unnecessary disclosures.


WOCCU Urges Proportionality for Credit Unions in Basel Pillar 3 Disclosures

WOCCU urged the Basel Committee to adopt a proportional regulatory approach in its recent comment letter on the Basel Committee on Banking Supervision's Technical Amendment: Pillar 3 Disclosure Requirements – Regulatory Treatment of Accounting Provisions.

Specifically with  the accounting for the credit quality of assets, WOCCU urged limiting reporting burdens for non-complex, community-based financial institutions by not allowing country-level disclosures for the geographic breakdown required under the disclosure.  This would reduce the compliance burden on most credit unions.

Further, WOCCU urged omitting Total Loss-Absorbing Capacity (TLAC)-related measures from a credit union's Pillar 3 disclosures for a credit union that is not required to issue TLAC instruments.

A copy of the comment letter can be viewed here.


Proportionality in Stress Testing Urged by WOCCU to Basel Committee on Proposal

World Council urges the Basel Committee on Banking Supervision (Committee) to adopt the principle of proportionality in its proposal on stress testing principles in its comment letter.  The Committee recently opened for comment its Consultative Document: Stress Testing Principles wherein it is moving to a shorter, higher-level articulation of existing principles which will allow for a more robust development of stress testing practices. WOCCU members have often reported “gold-plating” and excess supervision involving stress testing.  Accordingly, World Council is urging the Committee to finalize this standard in a manner that ensures that supervisory practices required for stress testing are commensurate with the risk profile and systemic importance of the supervised entity and to ensure credit unions are not unduly burdened by unnecessary oversight.

A copy of the comment letter can be viewed here.


WOCCU Urges Basel Committee to Consider Credit Union Difference for Treatment of Sovereign Exposures

WOCCU filed its comment letter on the Basel Committee on Banking Supervision’s (Committee) discussion paper The Regulatory treatment of sovereign exposures making various recommendations favorable for Credit Unions.  This discussion paper is derived from a report from by a high-level Task Force on Sovereign Exposures set up by the Committee to review the regulatory treatment of sovereign exposures and recommend potential policy options.



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)

IFRS 9 Loan Loss Accounting for Cooperative Financial Institutions

World Council comments to IASB regarding their International Financial Reporting Standard (IFRS) 9 Financial Instruments


Financial Stability Board

WOCCU Urges FSB to Consider Cooperative Structure on Proposals on Resolutions Regimes

The World Council of Credit Unions filed two comment letters with the Financial Stability Board (FSB) on their two Consultation Documents on Key Attributes of Effective Resolution Regimes:  1. Principles on Bail-in Execution; and 2. Funding Strategy Elements of an Implementable Resolution Plan
A copy of the Bail-In Principles Comment Letter can be viewed here and the Resolution Funding Strategies Proposal Comment Letter can be viewed here.

(2018-Feb 2)

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)