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 Revisions to the Credit Valuation Adjustment (CVA) Risk Framework February 25, 2020
European Banking Authority Revised Guidelines on Money Laundering and Terrorist Financing Risk Factors March 5, 2020
European Commission Action Plan on Anti-Money Laundering March 11, 2020
European Commission Financial Services - Improving Resilience Against Cyber Attacks (new rules) March 19, 2020
International Accounting Standards Board Comprehensive Review of the IFRS for SMEs
July 27, 2020


ENCU Comments on EBA Draft ITS on MREL and TLAC

ENCU responded to the European Bank Authority’s consultation regarding their Draft Implementing Technical Standards (ITS) on Disclosure and Reporting of MREL and TLAC. The draft ITS consisted of the EBA’s proposals for MREL/TLAC templates and tables that implement disclosure and reporting requirements. The EBA hopes to “optimise efficiency by institutions when complying with their disclosure and reporting obligations, to facilitate the use of information by authorities and market participants, and to promote market discipline.” The EBA requested feedback on the necessity, discrepancies, and clarity of specified tables and templates. ENCU emphasized its support for the EBA’s efforts to “to maximise efficiency by institutions when complying with their disclosure and reporting obligations, and to facilitate the use of information by authorities and market participants.” ENCU’s comments on this draft ITS can be found here.



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.


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)