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

2023-10-20

European Commission Proposes Head Office Tax System for SME’s

The European Commission has proposed giving small and medium enterprises (SMEs) the ability to interact with a single Head Office tax authority. The Commission is making this proposal to alleviate the complexity and compliance costs of cross border operations when operating with a permanent establishment in more than one member state. SMEs would have the opportunity to calculate their tax liability based only on the tax rules of the Member State allowing them to file one tax return.

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European Commission

European Commission Proposes Head Office Tax System for SME’s

2023-02-20

Commission Announces Platform on Sustainable Finance Members

On February 8, 2023, the European Commission announced its members for the new mandate of the Platform on Sustainable Finance via a published list. The Platform on Sustainable Finance is an advisory body that is “subject to the Commission’s horizontal rules for expert groups”,[1] and will advise the Commission on the implementation and usability of the EU taxonomy with three leading deliverables, including:

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European Commission

Commission Announces Platform on Sustainable Finance Members

2022-11-10

European Commission Advances Instant Payments in the EU and EEA Countries

On October 26, 2022, the European Commission adopted legislation it anticipates will make euro based instant payments more accessible in the EU through affordable, secure, and uninterrupted processing. The legislation, which is an amendment to the 2012 Regulation on the Single Euro Payments Regulation (SEPA), applies to all citizens and businesses in the EU and EEA countries that hold a bank account. The speed and ease of instant payments “help to significantly improve cash flow, and bring cost savings for businesses, especially for SMEs, including retailers”, with payments processing at anytime within ten seconds. According the press release from the Commission, only 11% of EU euro credit transfers were made using instant payments at the beginning of 2022, and the Commission hopes to increase that percentage through SEPA. The legislation is part of a commitment made through the Commission's 2020 Retail Payments Strategy, to improve instant payments.

SEPA is comprised of four requirements:

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European Commission

European Commission Advances Instant Payments in the EU and EEA Countries

2022-06-23

ENCU Touts Benefits of Credit Unions in EU Report on Social Taxonomy

The European Network of Credit Unions urged the Platform on Sustainable Finance of the European Commission to consider credit unions and the credit union not-for-profit cooperative model to be classified as their own social taxonomy based on the social benefits that credit unions provide to society.

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European Commission

ENCU Touts Benefits of Credit Unions in EU Report on Social Taxonomy

2022-02-28

European Council Updates Non-Financial Reporting Directive

The European Council amended the scope of the non-financial reporting directive (NFRD), which was proposed by the European Commission, in order to alleviate overburdensome reporting requirements for listed SMEs, and also giving SMEs time to adapt to the new rules. The objective of Commission’s proposal is intended to focus on deficits within the existing rules related to disclosure of non-financial information which the Commission not only believes will prevent a necessary transition to a sustainable economy, but “…was of insufficient quality and comparability to allow it to be properly taken into account by investors.” The Commission will adopt, by delegated act, a definition of sustainability reporting standards, thereby harmonizing sustainability data. The directive will be adopted subsequent technical advice given by certain European agencies and the European Financial Reporting Advisory Group (EFRAG).

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Council of the European Union, European Commission

European Council Updates Non-Financial Reporting Directive

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