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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
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

 

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:

  • “Primary gaps relating to firms' third-party risk management include a lack of clarity regarding respective bank and service provider responsibilities, insufficient monitoring of critical fourth parties, inadequate challenge or oversight from second lines of defence, and a lack of developed and tested business continuity plans.
  • Banks and supervisors are concerned that a lack of complete supply chain transparency may increase operational risk. Risk-management efforts are focused on immediate suppliers, though key risks stemming from outsourcing arrangements may be driven by suppliers further down the supply chain.
  • While several banks maintain formal exit strategies with respect to critical suppliers, they often lack sufficient detail and testing, and identifying the appropriate stage to execute a strategy can be unclear.
  • There are a range of tools for managing operational disruptions, such as the substitutability of a third-party service provider and contracting for enhanced resilience options or service levels offered by service providers. Exit strategies designed to guide transitions that occur over longer time periods may not be as useful as other tools for curing operational disruptions.”

The full newsletter is available here.

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