On a Whim…
Volume 15, Number 1
January 31, 2024
Advocacy News You Can Use
I was fortunate enough to visit a credit union in Tobago recently. It was an amazing visit, as the credit union was located in the hills in a somewhat isolated area. There were no other financial institutions in the vicinity. As I visited the credit union, its leaders let me know the credit union had ties to just about every house on the street leading up to it, either financing the construction of the house or offering financial services to someone in the house. There were many more in the area that I did not see.
What struck me is the incredibly close tie to the community the credit union had and how instrumental it was in building that community. I know this is not uncommon for credit unions that are community-based financial institutions, but it really impressed upon me just how influential one small credit union can be in a community without any other financial services. The sheer impact that responsible and affordable financial services can have on a community is truly staggering. None of those houses would be there without it. How many lives were changed by that credit union? It reinforced for me just how much credit unions are the fabric of their communities.
It is in that context that the Co-operative Credit Union League of Trinidad & Tobago is currently seeking reforms to help strengthen the cooperative model. Their efforts are moderately met by policy makers that do not understand the importance of allowing the credit union cooperative model to work and to truly maximize its potential. They don’t fully appreciate the ability of a small credit union to build communities in underserved and rural areas. If policymakers truly desire to benefit the citizens of their country, it is imperative that they look to the benefits of the credit union cooperative model and work to support it, as opposed to just adopting something every now and then on a whim. The name of that excellent credit union by the way…Whim Credit Union.
World Council Touts Advocacy Successes, Focuses on 2024
World Council of Credit Unions took stock of the many issues that arose during 2023 and the role of International Advocacy in shaping regulations to grow and strengthen credit unions. Notably, World Council notes advocacy victories in
- The G20 including proportionality in the Leaders’ Declaration on Sustainability Standards.
- Presenting at the United Nations on the role of credit unions and cooperatives in advancing financial inclusion.
- The inclusion of WOCCU-advocated proportionality measures in the ISSB’s inaugural climate risk and sustainability disclosures.
- The inclusion of the support of financial inclusion in the G20 Leaders’ Declaration (and the corollary role that credit unions can play in advancing financial inclusion).
- Various victories with the European Union on Basel III, payments, operational resilience, and others.
These advocacy victories directly result in the ability of the credit union cooperative model to be supported by appropriately tailored regulatory frameworks that enable credit unions to thrive. World Council continues to be the only organization representing credit unions at the international standard setting level. The involvement in these issues is informing our outlook on various issues that will receive attention in 2024, including climate change, payments, cybersecurity, cryptocurrencies and others.
World Council’s 2024 Outlook and 2023 Year-end Summary can be viewed here.
Why this matters to your credit union: These advocacy victories will help to support the credit union cooperative model, reduce regulatory burden and help to support proper tailoring of national-level rulebooks for credit unions.
FSB Sets Out 2024 Work Programme
The Financial Stability Board (FSB) published its work programme for 2024. Priority areas of work and new initiatives, including deliverables to the Brazilian G20 Presidency, include:
- Supporting global cooperation on financial stability. The FSB continues to promote financial stability in a rapidly changing environment, in which vulnerabilities in the global financial system continue to be elevated, reflecting high interest rates and an uncertain growth outlook, while vulnerabilities from structural change continue to emerge in areas such as climate change, cyber, and crypto-asset markets.
- Completing resolution reforms. The FSB will continue its work to promote the full implementation of the Key Attributes of Effective Resolution Regimes for Financial Institutions across all sectors. The focus will be to address the lessons learned from the March 2023 banking turmoil, including work on deposit behavior and the role of technology and social media; and on interest rate and liquidity risk in the financial system. In 2024, the FSB will also finalize its proposals for a set of resources and tools to support the resolution of a central counterparty (CCP) and publish the list of insurers subject to the resolution planning standards.
- Enhancing the resilience of NBFI. The FSB will continue to advance its work programme for enhancing NBFI resilience, which it is carrying out together with the standard-setting bodies and international organizations. This includes exploring policy recommendations or policy options for non-bank financial leverage; enhancing liquidity preparedness of non-bank market participants for margin and collateral calls; and conducting new work on the functioning and resilience of repo markets.
- Enhancing cross-border payments.The G20 roadmap for enhancing cross-border payments coordinated by the FSB, contains a comprehensive set of actions and a framework for monitoring progress toward achieving the quantitative targets that have been set for the end of 2027. As part of this, in 2024, the FSB will issue recommendations to promote alignment and interoperability in data frameworks related to cross-border payments and develop recommendations to strengthen the consistency of regulation and supervision of banks and non-banks providing cross-border payment services.
- Harnessing the benefits of digital innovation while containing its risks. A key focus for 2024 and beyond is on ensuring the effective implementation of the agreed global regulatory and supervisory framework for crypto-asset activities and markets and for global stablecoin arrangements. The FSB will also complete work on the financial stability implications of tokenization; prepare a report for the G20 on recent developments in AI and their potential implications for financial stability; and, in its efforts to enhance cyber resilience, design a format for incident reporting exchange (FIRE) to promote greater convergence in financial institutions’ reporting of incidents to financial authorities.
- Addressing financial risks from climate change. The FSB will continue to coordinate international work through its roadmap for addressing climate-related financial risks. Work this year will include analysis of the relevance of transition plans for financial stability and, for the G20, a stock-take of regulatory and supervisory initiatives related to the identification and assessment of nature-related financial risks. The FSB will also prepare a further progress report on achieving consistent climate-related financial disclosures.
A copy of the programme can be viewed here.
Why this matters to your credit union: The issues that the Financial Stability Board focuses on for 2024 are some of the most pressing issues in the regulatory operating environment. From sustainable finance to cybersecurity to changes as a result from the recent financial instability will all impact regulations for credit unions.
WOCCU International Advocacy releases 2024 Global Regulatory Update
If technological innovations are going to truly boost financial inclusion worldwide, international standard setting bodies and national-level regulators must consider the institutions offering digital financial products and services as much as they examine how those deliverables are offered when contemplating new compliance requirements.
Were regulations to be written only for the large international banks as innovation and new technologies evolve, credit unions and other community-based cooperative institutions would be excluded from key aspects of the financial services market.
That’s the overriding theme of World Council of Credit Unions’ (WOCCU) 2024 Global Regulatory Update, which stresses how important it is for WOCCU and other credit union associations around the globe to advocate for fair, proportional treatment from the policymakers developing our digital regulatory environment.
“If international standard setters truly want to ensure emerging digital technologies play a major role in reaching financial inclusion goals, they must recognize that credit unions will reach more unbanked and underserved consumers through these innovations than any other type of financial institution,” said Erin O’Hern, WOCCU International Advocacy and Regulatory Counsel. “They must provide timely guidance to national-level regulators that levels the playing field for our community-based organizations, so they can properly estimate the compliance resources needed to develop and maintain digital products and services.”
World Council’s Global Regulatory Update is put out on an annual basis to help credit unions and financial cooperatives prepare for the compliance issues most likely to impact them in the year ahead. The new edition also covers several other leading regulatory issues affecting credit unions across the globe, including:
- Climate Change and Sustainable Finance.
- Cybersecurity and Operational Resilience.
- Payments.
- Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT).
You can read World Council’s 2024 Global Regulatory Update in its entirety by clicking here.
An interview with Erin O'Hern and Andrew Price is also available to listen to on the January edition of The Global Credit Union Podcast.
Why this matters to your credit union: The Global Regulatory Update is issued every year to provide a forward looking perspective on critical regulatory issues for credit unions. Insight into these issues from an international perspective will forewarn of pending changes at that national level.
World Council of Credit Unions in Trinidad & Tobago Urging Reforms to Support Credit Unions
World Council of Credit Unions’ (WOCCU) Senior Vice President of International Advocacy and General Counsel Andrew Price visited Trinidad and Tobago at the request of the Co-operative Credit Union League of Trinidad & Tobago (CCULTT) to meet with numerous stakeholders and assist in crafting reforms that will improve and strengthen the Caribbean nation’s vibrant credit union system.
The Cabinet of Ministers of Trinidad & Tobago in January 2019 appointed a Ministerial Sub-Committee to examine the credit union sector and make recommendations to strengthen it. Their recommendations have resulted in a Draft Policy Proposal Document (PPD) to form an Independent Co-operative Authority to regulate the country’s cooperative sector.
The Sub-Committee also received input from the World Bank as part of the process. Input from WOCCU, as the international body representing credit unions, is critical at this juncture to ensure the legislative decision-making process considers the appropriate approach for credit unions and their members.
WOCCU and the Caribbean Confederation of Credit Unions (CCCU), our direct member in the region, have been working jointly with CCULTT to bring international experience and global best practices to the policymaking process.
“We applaud the efforts of Trinidad and Tobago to evolve and strengthen the regulatory framework for credit unions. If done correctly, this is a real opportunity to maximize the ability of community-based financial institutions to improve financial inclusion, which is key to enhancing the welfare and local economic growth for the citizens of Trinidad & Tobago,” said Andrew Price, Senior Vice President of Advocacy and General Counsel, World Council of Credit Unions.
“It is important that policymakers understand the unique nature of credit unions as member-owned financial cooperatives and how that model can enhance services to underserved and marginalized communities. We know from our international networks and experience that properly tailored regulations that enhance safety and soundness are the best way to achieve these results,” said Joseph Remy, President of CCULTT and a Board Director for both CCCU and WOCCU.
Other reforms under consideration, such as the adoption of deposit insurance, will help advance and modernize regulations for credit unions. There are 129 credit unions, serving approximately 753,000 members and representing approximately US $3 million in assets in Trinidad & Tobago. It is one of the most vibrant systems in the Caribbean. All three organizations, WOCCU, CCULTT and CCCU, will continue to work with policymakers on the reforms moving forward.
Why this matters to your credit union: World Council supports all of its member countries to improve the regulatory operating environment for credit unions. Changes in any country can sometimes influence or affect positive changes in other countries, particularly on a regional basis.
Andrew T. Price, Esq. |