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	Public Consultation Recommendation 16 on Payment Transparency	May 3, 2024

Recent News on our Competent Authorities

2022-02-01

Supervisory Authorities Bolster the Importance of Financial Education

Financial education got a boost last month when both the European Commission, and the three European Supervisory Authorities (EBA, ESMA and EIOPA), collectively called the ESAs, published initiatives related to financial competence and financial digitalization education, respectively. On January 11, 2022, the European Commission and the OECD’s International Network on Financial Education published a joint EU/OECD-INFE financial competence framework for adults. This was a continuation of measures that were announced in Action 7 of the 2020 capital markets union action plan. The joint EU/OECD-INFE’s, Financial Competence Framework for Adults in the European Union, “aims to improve individuals' financial skills so that they can make sound decisions regarding their personal finances. It will support the development of public policies, financial literacy programmes and educational materials by Member States, educational institutions and industry. It will also support the exchange of good practices by policy makers and stakeholders in the EU.”

Tags
OECD, European Banking Authority, European Commission

Supervisory Authorities Bolster the Importance of Financial Education

2020-09-22

ENCU Urges EBA to Address De-risking

The European Banking Authority (EBA) called for input to understand the impact of de-risking on financial institutions and customers. The European Network of Credit Unions responded to the EBA’s directed questions and highlighted that credit unions are often the subject of de-risking by banks. Reasons for this include perceived regulatory burden and risks associated with AML/CFT requirements and the potential to eat into profits; confusion surrounding responsibility associated with AML/CFT requirements; and conflicting privacy standards in various countries creating difficulty navigating cross-border operations. ENCU noted that de-risking has reduced access to bank services causing credit unions to seek these services from second and third tier banks, which in turn has proven to be costly and burdensome, and therefore a deterrent to the provision of these services to its members.

Tags
Comment Letter, European Banking Authority

2020-02-21

ENCU Comments on EBA Draft ITS on MREL and TLAC

ENCU responded to the European Bank Authority’s consultation regarding their Draft Implementing Technical Standards (ITS) on Disclosure and Reporting of MREL and TLAC. The draft ITS consisted of the EBA’s proposals for MREL/TLAC templates and tables that implement disclosure and reporting requirements. The EBA hopes to “optimise efficiency by institutions when complying with their disclosure and reporting obligations, to facilitate the use of information by authorities and market participants, and to promote market discipline.” The EBA requested feedback on the necessity, discrepancies, and clarity of specified tables and templates. ENCU emphasized its support for the EBA’s efforts to “to maximise efficiency by institutions when complying with their disclosure and reporting obligations, and to facilitate the use of information by authorities and market participants.” ENCU’s comments on this draft ITS can be found here.

Tags
Comment Letter, ENCU, European Banking Authority

ENCU Comments on EBA Draft ITS on MREL and TLAC

2020-02-11

European Banking Authority Releases Consultation on Revised AML/CFT Guidelines

The European Banking Authority (EBA) issued a public consultation on its draft Guidelines regarding revised money laundering and terrorist financing (ML/FT) risk factors. “This update takes into account changes to the EU Anti Money Laundering and Counter Terrorism Financing (AML/CFT) legal framework and new ML/TF risks, including those identified by the EBA’s implementation reviews.” The Guidelines provide factors for institutions to consider when assessing ML/FT risks, guidance on how to adjust due diligence measures to mitigate ML/FT risks once they’re identified, and support supervision efforts to assess a competency of financial institutions risk assessments and AML/CFT policies and procedures. Some of the key changes to the EBA’s guidance includes enhanced due diligence for high-risk third countries, as well as guidance on crowdfunding, corporate finance, PISPs and AISPs and currency exchange activities. The EBA’s press release on this consultation can be found here.

Tags
European Banking Authority

European Banking Authority Releases Consultation on Revised AML/CFT Guidelines

2020-01-16

ENCU Responds to EBA Consultation on Draft Implementing Technical Standard on Supervisory Reporting

The European Banking Authority (EBA) solicited comment on their Draft Implementing Technical Standards on supervisory reporting requirements for institutions under Regulation (EU) No 575/2013 (Draft ITS), which addresses “institutions’ compliance with prudential requirements as put forward by the CRR and related technical standards as well as additional financial information required by supervisors to perform their supervisory tasks.” Additionally, the EBA the Draft ITS revised reporting modules to adhere to two amendments to the CRR made in 2019 regarding liquidity, leverage and large exposures; and amending the’ backstop regulation’ “which sets out uniform minimum levels of coverage to ensure that institutions have sufficient loss coverage for future non-performing exposures (NPEs)” The European Network of Credit Unions (ENCU) stated its support for the EBA’s updates and revisions to its Draft ITS, and the incorporation of proportionality in the reporting requirements, however, ENCU urged EBA to encourage finalization of the Basel standards using proportionality in the reporting requirements. This consultation ran parallel with the EBA’s consultation on ITS on public disclosures; and for more information on ENCU’s response to this consultation, please see our blog post here. ENCU's response to the EBA Consultation on Draft Implementing Technical Standards on Supervisory Reporting can be viewed here.

Tags
Comment Letter, ENCU, European Banking Authority

ENCU Responds to EBA Consultation on Draft Implementing Technical Standard on Supervisory Reporting

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