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 Banking Authority	Regulatory Technical Standards EU's New AML/CFT Regime	June 6, 2025

Recent News on our Competent Authorities

2024-10-31

FATF Issues Public Consultation on AML/CFT and Financial Inclusion

The Financial Action Task Force (FATF) recently issued a public consultation with proposed changes intended to better promote financial inclusion. Comments are due to FATF by December 6, 2024. The proposed revisions span several different FAFT Recommendations and Interpretive Notes, including Recommendation 1, 10 and 15. The revisions include an increased focus on proportionality and more streamlined measures regarding the risk-based approach. The new revisions also address non-face-to-face customer-identification and transactions.

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FATF

FATF Issues Public Consultation on AML/CFT and Financial Inclusion

2024-10-25

Basel Committee Releases Updated Report on 2023 Banking Turmoil

The Basel Committee on Banking Supervision issued a progress report to the G20 Finance Ministers and Central Bank Governors regarding their analysis of the 2023 banking turmoil. It addresses the liquidity-related issues including distressed banks’ outflow rates and the role of the supervisory monitoring tools.

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Bank of International Settlements

Basel Committee Releases Updated Report on 2023 Banking Turmoil

2024-10-23

Financial Stability Institute Issues Paper on Liquidity Stress Tests

Liquidity is a top risk measured and monitored by individual financial institutions and prudential supervisors. The Financial Stability Institute produced a detailed report recently issued by the Bank of International Settlements on the variations and importance of strong liquidity stress tests. The report acknowledges the continued evolution of liquidity challenges given changes to the overall sector, technology and consumer behavior.

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Bank of International Settlements

Financial Stability Institute Issues Paper on Liquidity Stress Tests

2024-09-26

BIS Releases Executive Summary on the Impact of Digitalisation on Operational Continuity in Resolution

Bank of International Settlements (BIS) issued an executive summary outlining Operational Continuity in Resolution (OCiR). OCiR refers to a financial institution in resolution’s ability to continue the critical shared services that are needed to maintain or facilitate the wind-down of a financial institution’s critical functions.

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Bank of International Settlements

BIS Releases Executive Summary on the Impact of Digitalisation on Operational Continuity in Resolution

2024-09-25

Basel Committee Meeting Reviews Recent Risks

The Basel Committee on Banking Supervision met in September to discuss recent market trends and disruptions as well as key supervisory initiatives. The Committee noted several spikes in market volatility in July and August related to large, levered positions and the interconnections with non-bank financial intermediaries. The Committee noted the importance of operational resilience and managing third-party risks.

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Basel

Basel Committee Meeting Reviews Recent Risks

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