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
FATF	Risk-Based Guidance on Recommendation 25 (Beneficial Ownership and Transparency of Legal Arrangements)	December 8, 2023
Committee on Payments and Market Infrastructures (Bank for Int'l Settlements)	Linking Fast Payment Systems Across Borders: Considerations for Governance and Oversight	December 13, 2023
European Commission	Critical ICT Third-Party Service Providers - Criteria & Fees	December 14, 2023
Basel Committee	Disclosure of Banks' Cryptoasset Exposures	January 31, 2024
Basel Committee	Discussion Paper on Digital Fraud	February 16, 2024
Basel Committee	Disclosure Framework for Climate-Related Financial Risk	February 29, 2024

Recent News on our Competent Authorities

2023-12-04

WOCCU Applauds Proportionality in FSB’s Toolkit on Vendor Management

WOCCU advocated proportionality was included in the Financial Stability Board’s (FSB) Toolkit for Enhancing Third-party Risk Management and Oversight. The proportionality language makes it clear that many of the tools are unsuitable for smaller financial institutions and calls for the tailoring of the rules.

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Financial Stability Board

WOCCU Applauds Proportionality in FSB’s Toolkit on Vendor Management

2023-11-29

Basel Committee Consults on Disclosures for Climate-related Financial Risk

The Basel Committee on Banking Supervision issued a public consultation paper on a Pillar 3 disclosure framework for climate-related financial risks.

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Basel

Basel Committee Consults on Disclosures for Climate-related Financial Risk

2023-11-29

Basel Committee Provides Details on Climate-Related Financial Risk Management

In a recent newsletter the Basel Committee provided additional information regarding the status of implementation of the Principles for the effective management and supervision of climate-related financial risks (Principles) and current gaps.

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Basel

Basel Committee Provides Details on Climate-Related Financial Risk Management

2023-11-28

FSB Report on Multifunction Crypto-Asset Intermediaries

The Financial Stability Board (FSB) recently published a report on the financial stability implications of multifunction crypto-asset intermediaries (MCIs). MCIs are individual firms or groups of affiliated firms that provide crypto-asset services, products and functions usually around a trading platform. In many cases MCI vulnerabilities are similar to those of traditional finance. However, these vulnerabilities can be amplified by limited controls and operational transparency. MCI vulnerabilities could impact traditional financial systems through transmission channels.

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Financial Stability Board

FSB Report on Multifunction Crypto-Asset Intermediaries

2023-11-20

Regulator Diversity and Inclusion Round-Up

Financial service regulators globally continue to look at the impact of diversity and inclusion within their own organization and credit unions. Regulators recognize the impact diversity and inclusion has on safety and soundness. Earlier this year, the Financial Conduct Authority (FCA) in the United Kingdom set out proposals to increase diversity and inclusion, reduce groupthink and maximize talent. The proposals noted that increase in diversity and inclusion in regulated financial services firms can produce better internal governance, decision making and risk management practices. The new rules and guidance identify that bullying and sexual harassment amongst other forms of misconduct pose a risk to a healthy firm culture.

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