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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
Financial Action Task Force FATF Guidance on Beneficial Ownership (Recommendation 24) December 6, 2022
Financial Action Task Force Revision of R25 and its Interpretive Note
December 6, 2022
IFRS Proposals to Update Accounting Standards for SMEs March 7, 2023
 

Recent News on our Competent Authorities

 

2022-11-10

European Council Reaches Position on CRD and CRR Amendment Proposals

On November 8, 2022, the European Council reached a decision on its general approach to Basel III regulatory reforms, namely proposals on amendments to the capital requirements directive (CRD) and the capital requirements regulation (CRR). The Council hopes that by implementing these reforms, it will “boost the resilience of banks operating in the Union and strengthen their supervision and risk management”.

The “output floor” which uses internal models to calculate minimum capital requirements, will apply to both individual and group banking levels, however, member states will have discretion, within its own country, to apply the output floor at the highest level of consolidation. In addition to enhanced technical improvements to credit and market risk and several other improvements, the Council’s position on the implementation of Basel III reforms will enhance proportionality rules for small banks, specifically for disclosure requirements as they pertain to small and non-complex financial institutions. The European Commission previously presented its proposal on the review of the CRD and CRR regulations on October 27, 2021-- next steps include negotiations with the European Parliament to finalize a version of the texts and finalizing the implementation of Basel III international agreements into EU law.

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Basel, Council of the European Union
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European Council Reaches Position on CRD and CRR Amendment Proposals

2022-07-01

European Parliament and Council Reach Provisional Agreement on MiCA

On June 30, 2022, the European Parliament and the European Council Presidency reached a provisional agreement on the markets in crypto-assets (MiCA) proposal. The proposal encompasses unbacked crypto-assets issuers, stablecoins, trading venues and crypto-asset wallets. Although national-level regulators have already begun to implement crypto-asset legislation, it is the first time that crypto-assets, crypto-assets issuers and crypto-asset service providers are all under a regulatory framework at the EU level.

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Council of the European Union
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European Parliament and Council Reach Provisional Agreement on MiCA

2022-06-30

EU Reinforces Rules on Crypto Asset Transfers to Reduce the Use of Cryptocurrencies for Crime

On June 29, 2022, the European Council Presidency and the European Parliament reached a provisional agreement and extended the of the scope of a proposal by way of  the "travel rule", which updates transfer of fund rules to include transfer of crypto assets. The rule aims to, “…ensure financial transparency on exchanges in crypto-assets and will provide the EU with a solid and proportional framework that complies with the most demanding international standards on the exchange of crypto-assets, in particular recommendations 15 and 16 of the Financial Action Task Force (FATF), the global money laundering and terrorist financing watchdog.”

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Council of the European Union
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EU Reinforces Rules on Crypto Asset Transfers to Reduce the Use of Cryptocurrencies for Crime

2022-05-17

European Council Takes Position on 2030 Policy Program ‘Path to the Digital Decade’

On May 11, 2022, the European Council adopted its position on the 2030 Policy Programme “Path to the Digital Decade’, which is designed to “strengthen the EU’s digital leadership” through inclusive and sustainable digital policies. Once the European Parliament has confirmed its position, negotiations between Parliament and Council presidency can take place.

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Council of the European Union
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European Council Takes Position on 2030 Policy Program ‘Path to the Digital Decade’

2022-05-17

European Council Approves New Law to Promote the Availability of Data

On May 16, 2022, the European Council approved the Data Governance Act, “to promote the availability of data and build a trustworthy environment to facilitate their use for research and the creation of innovative new services and products.” The Act aims to create a system where the reuse of specific public-sector data categories (trade secrets, personal data and data protected by intellectual property rights), are protected to safeguard privacy and confidentiality. This act accompanies the 2019 Open Data Directive, which covers other data categories including but not limited to material held by ministries, state agencies, municipalities, and organizations largely funded by or under the control of public authorities, i.e., meteorological institutes. A single access point consisting of a searchable electronic register of public-sector data will be made available by the European Commission. The Act further intends to implement a framework for data intermediation services via a digital services platform to provide a secure data sharing network for individuals and companies; simplify voluntary data availability for the common good or “objectives of general interest” (i.e. medical research projects), through a national register; and create safeguards for personal data.

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Council of the European Union
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European Council Approves New Law to Promote the Availability of Data

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