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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

 

G20 Reaffirms WOCCU Advocated Support for Financial Inclusion

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G20

The G20 adopted the G20 Rome Leaders’ Declaration wherein it reaffirmed its support to supporting WOCCU advocated focus on financial inclusion.  WOCCU urged the G20 to focus on the importance of proportionality for the purposes of allowing credit unions to increase financial inclusion. The G20 reaffirmed its commitment to enhancing financial inclusion of vulnerable and underserved segments of society and endorsed the G20 Menu of Policy Options focused on digital financial literacy and financial consumer protection.  The G20 also reiterated its support for the e G20 2020 Financial Inclusion Action Plan which includes Principle 3 which provides for providing an enabling and proportionate legal and regulatory framework for digital financial inclusion, taking into account relevant G20 and international standard setting body standards and guidance.

Their goal is to provide a guide for policymakers in their efforts to lay the ground for new financial inclusion strategies in the post-pandemic world.  Further, the G20 endorsed the risk-based approach of the Financial Action Task Force which aims to promote financial inclusion and ensure legitimate cross-border payments.  The focus on adopting a risk-based approach is welcomed by WOCCU as it focuses on the importance of proportional regulations tailored to the size, risk and complexity of credit unions.

 A summary of the issues addressed by the Leaders’ Declaration are as follows:

Financial Inclusion:   The G20 reaffirmed commitment to enhancing digital financial inclusion of vulnerable and underserved segments of society, including micro, small and medium-sized enterprises (MSMEs), carrying forward the work of the Global Partnership for Financial Inclusion (GPFI) and implementing the G20 2020 Financial Inclusion Action Plan. We endorse the G20 Menu of Policy Options for digital financial literacy and financial consumer and MSME protection “Enhancing digital financial inclusion beyond the COVID-19 crisis”, with the aim to provide a guide for policymakers in their efforts to lay the ground for new financial inclusion strategies in the post-pandemic world.

The G20 also reiterated its support for the  G20 2020 Financial Inclusion Action Plan which includes Principle 3 which provides for providing an enabling and proportionate legal and regulatory framework for digital financial inclusion, taking into account relevant G20 and international standard setting body standards and guidance.

AML/CFT:  The G20 reaffirmed its full support for the Financial Action Task Force (FATF) and the Global Network and recognized that effective implementation of Anti-Money Laundering/Countering the Financing of Terrorism and Proliferation (AML/CFT/CPF) measures is essential for building confidence in financial markets, ensuring a sustainable recovery and protecting the integrity of the international financial system. They stressed the relevance of the risk-based approach of the FATF recommendations with the aim to ensure legitimate cross-border payments and to promote financial inclusion. They confirmed support for strengthening the FATF recommendations to improve beneficial ownership transparency and call on countries to fight money laundering from environmental crime, particularly by acting on the findings of the FATF report.

Sustainable Finance:  The G20 noted that sustainable finance is crucial for promoting orderly and just transitions towards green and more sustainable economies and inclusive societies, in line with the 2030 Agenda for Sustainable Development and the Paris Agreement. They welcomed the establishment of the G20 Sustainable Finance and endorsed the G20 Sustainable Finance Roadmap and the Synthesis Report. The Roadmap, initially focused on climate, is a multi-year action-oriented document, voluntary and flexible in nature, which will inform the broader G20 agenda on climate and sustainability.  The G20 also noted that it is focused on expanding the scope of sustainable finance to include social matters.

Payments:  They welcomed the progress reported against milestones set for 2021 by the G20 Roadmap to enhance cross-border payments, and we endorse the ambitious but achievable quantitative global targets for addressing the challenges of cost, speed, transparency and access by 2027 set out in the FSB report. They called on public authorities and the private sector to work together to make the practical improvements to achieve these goals.

Stablecoins/Digital Currencies:  The G20 reiterated that no so-called “global stablecoins” should commence operation until all relevant legal, regulatory and oversight requirements are adequately addressed through appropriate design and by adhering to applicable standards. They encouraged jurisdictions to progress in the implementation of the FSB High-Level Recommendations, and standard setting bodies to complete their assessment of whether to make any adjustments to standards or guidance in light of the FSB Recommendations. They focused the Committee on Payments and Market Infrastructures, Bank for International Settlements Innovation Hub, IMF and World Bank to continue deepening the analysis on the potential role of central bank digital currencies in enhancing cross-border payments and their wider implications for the international monetary system.

Digitalization:  The G20 recognized the importance of policies to create an enabling, inclusive, open, fair and non-discriminatory digital economy that fosters the application of new technologies, allows businesses and entrepreneurs to thrive, and protects and empowers consumers, while addressing the challenges related to privacy, data protection, intellectual property rights, and security. Mindful of the need to support a better inclusion of MSMEs in the digital economy, they reinforced their actions and international cooperation towards the digital transformation of production, processes, services and business models, also through the use of consensus-based international standards and the improvement of consumer protection, digital skills and literacy.

Gender Equality and Women’s Empowerment. They reaffirmed commitment to gender equality and emphasize the pivotal role of women’s and girls’ empowerment and leadership at all levels for inclusive and sustainable development. The G20 committed to putting women and girls, who have been disproportionately affected by the pandemic, at the core of efforts to build forward better.

International Taxation:  The final political agreement as set out in the Statement on a Two Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy and in the Detailed Implementation Plan, released by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) on 8 October, is a historic achievement through which the world will establish a more stable and fairer international tax system. They called on the OECD/G20 Inclusive Framework on BEPS to swiftly develop the model rules and multilateral instruments as agreed in the Detailed Implementation Plan, with a view to ensure that the new rules will come into effect at global level in 2023.



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