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	Sustainable Finance - Environment, Social and Governance Ratings and Sustainability Risks In Credit Ratings	June 6, 2022
European Commission	Open Finance Framework - Enabling Data Sharing and Third Party Access in the Financial Sector	June 7, 2022
European Commission	Distance Marketing of Consumer Financial Services - Review of EU Rules	June 25, 2022
Financial Stability Board	Supervisory and Regulatory Approaches to Climate-Related Risks: Interim Report	June 30, 2022
IFRS	General Requirements for Disclosure of Sustainability-related Financial Information	July 29, 2022
IFRS	Climate-related Disclosures	July 29, 2022
European Commission	Payment Services - Review of EU Rules	August 2, 2022

Recent News on our Competent Authorities

2022-04-04

Basel Committee Releases Newsletter on Third- and Fourth-Party Risk Management and Concentration Risk

The Basel Committee on Banking and Supervision released a newsletter underscoring internal discussions and outreach sessions took place to improve third- and fourth-party risk management and concentration risk to support day-to-day activities for banks and supervisors. The newsletter further highlighted concerns regarding operational risks that have emerged during the pandemic related to third-party provided technology-based services. Last month the Basel Committee, in response to some of these issues, released Principles for Operational Resilience (POR) and revised its Principles for the Sound Management of Operational Risk (PSMOR). During the Committee’s outreach sessions with private sector participants and supervisors, it was noted that:

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Basel

2022-03-03

Basel Committee Releases Newsletter on COVID-19 Related Credit Risk Issues

On March 2, 2022, the Basel Committee on Banking Supervision issued a newsletter on COVID-19 related credit risk issues they believe will be helpful to support the day-to-day activities of banks and supervisors. The newsletter addresses: the Committee’s intention to continue to assess credit risk and asset quality by maintaining their monitoring of bank practices, in addition to administering necessary provisions; observations from supervisors regarding policies and practices across banks' credit risk governance and credit risk models; and challenges to assessing the creditworthiness of borrowers due to the COVID-19 pandemic.

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Bank of International Settlements, Basel

2022-02-18

WOCCU Urges Proportionality in Climate Principles

The World Council of Credit Unions urged the Basel Committee on Banking Supervision to include proportionality in its Principles for the Effective Management and Supervision of Climate Related Financial Risks. The comments came as a response to the Basel Committee’s request for comments on its efforts to address the physical and transition risks that could affect the safety and soundness of individual financial institutions as a result of climate-related financial risks. The Basel Committee is looking to strengthen the regulation, supervision, and practices of financial institutions worldwide.

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Basel

WOCCU Urges Proportionality in Climate Principles

2022-02-16

The Basel Committee’s Oversight Body Renews its Commitment to Basel III Implementation

On February 9, 2022, the Basel Committee’s oversight body, the Group of Central Bank Governors and Heads of Supervision (GHOS), met to not only reappoint Pablo Hernández de Cos as Chair for a second term, but to reaffirm its “commitment to implementing all aspects of the Basel III framework”. The GHOS reviewed progress of the Basel III implementation process and pushed for implementation in “a full, timely and consistent manner to provide a regulatory level playing field for internationally active banks”; which was followed by full agreement from all members. Under the purview of the Regulatory Consistency Assessment Programme, the GHOS further obligated the Basel Committee to continue to monitor implementation of the framework. The GHOS is currently looking to fill its Chair vacancy as their previous Chairman, François Villeroy de Galhau, stepped down to accept his appointment as Chair of the Board of Directors of the Bank for International Settlements.

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Bank of International Settlements, Basel

The Basel Committee’s Oversight Body Renews its Commitment to Basel III Implementation

2022-01-28

WOCCU Congratulates Neil Esho On Secretary General Appointment to the Basel Committee

World Council congratulates Neil Esho on his newly appointed position and the Basel Committee on Banking Supervision. The Basel Committee announced that their former Deputy Secretary General, has been appointed to Secretary General. Esho’s three-year term will begin next month in February 2022. World Council has previously met with Esho, then Deputy Secretary General, in March 2019 to support proportionality and discuss the effect of overburdensome regulations on credit unions. World Council followed the meeting with a letter urging Esho and the Basel Committee to “issue additional guidance on proportionality in regulation in the form of a set of high-level principles or weighing-factors on when less complex regulatory approaches can be warranted, such as:

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Basel

WOCCU Congratulates Neil Esho On Secretary General Appointment to the Basel Committee

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