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
Basel Committee on Banking Supervision Introduction of Guidelines on Interacation and Cooperation Between Prudential and AML/CFT Supervision February 6, 2020
European Banking Authority Disclosure and Reporting of MREL and TLAC February 22, 2020
Basel Committee on Banking Supervision Revisions to the Credit Valuation Adjustment (CVA) Risk Framework February 25, 2020
European Commission Financial Services - Improving Resilience Against Cyber Attacks (new rules) March 19, 2020


ENCU Comment Letter on EBA Consultation on Supervisory Requirements for Market Risk

The European Network of Credit Unions (ENCU) responded to the European Banking Authority's public consultation regarding specific supervisory reporting requirements for market risk. These requirements are the initial elements of the Capital Requirements Regulation's (CRR2) launch of the Fundamental Review of the Trading Book. The consultation serves to "include  proposals for a thresholds template, providing insights into the size of institutions’ trading books and the volume of their business subject to market risk, and a summary template, reflecting the own funds requirements under the ‘Alternative Standardised Approach’ for market risk (MKR-ASA)."


WOCCU Responds to Public Consultation on Implementing Final Basel III Reforms

The European Commission has opened a public consultation regarding the next stages in their implementation of final Basel III reforms in the EU. The EC aims to use the consultation as a means to shape the next wave of banking regulation proposals for next year. According to the EC, “the Commission services aim to gather stakeholders’ views on specific topics in the areas of credit risk, operational risk, market risk, credit valuation adjustment risk, securities financing transactions as well as in relation to the output floor.” The EC expects the solicited comments will ensure “convergent and consistent supervisory practices across the Union and alleviating the administrative burden.”


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 FSB Comments on Too Big To Fail Reforms

(2019-June. 21)


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)