View All Comment Letters and Position Papers

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
European Commission Public Consultation on Consumer Credit Agreements - Review of EU Rules October 6, 2021
IFRS Management Commentary November 23, 2021

Recent Comment Letters


ENCU Comments on EC Consultation on Distance Marketing of Consumer Financial Services

The European Network of Credit Unions (ENCU) supports the European Commission’s objective to ensure “a framework for the distance marketing of financial services that is future proof, protects consumers in a digital environment, delivers a level playing field and reduces unnecessary burden for financial service providers.”



Comments to International Standard Setting Bodies


Financial Action Task Force (FATF)

WOCCU Comments on FATF Mitigating the Unintended Consequences of its Standards

World Council wrote FATF to let  agency know it fully supports a new project to study and mitigate the unintended consequences resulting from the incorrect implementation of the FATF Standards.
(2021-April 20)

International Accounting Standards Board (IASB)

WOCCU Comments on IFRS Consultation Paper on Sustainability Reporting

World Council urges the IASB to consider smaller financial institutions and the burden that additional reporting may impose.
(2020-Dec 30)

Financial Stability Board

WOCCU Comments on FSB Discussion Paper on Outsourcing and Third-party Relationships

WOCCU urges FSB to consider proportional and risk-based regulation and supervision as the most effective way of regulating smaller institutions such as credit unions.

(2021-January 8)

Basel Committee on Banking Supervision

WOCCU Comments on Basel Committee Revisions to Principles for Sound Management of Operational Risk

WOCCU supports overall changes proposed while encouraging Basel Committee to emphasize that this model should be adequately and proportionally used by financial institutions to manage every kind of operational risk sub-category, including ICT risk.