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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
European Commission Distance Marketing of Consumer Financial Services - Review of EU Rules June 25, 2022
IFRS General Requirements for Disclosure of Sustainability-related Financial Information July 29, 2022
IFRS Climate-related Disclosures July 29, 2022
Financial Action Task Force Call for advice to the European Banking Authority (EBA) regarding the review of Directive 2014/17/EU1 (Mortgage Credit Directive) August 1, 2022
European Commission Payment Services - Review of EU Rules August 2, 2022
European Commission Open finance framework – enabling data sharing and third party access in the financial sector August 2, 2022
Basel Committee on Banking Supervision Prudential Treatment of Banks' Cryptoasset Exposures September 30, 2022
 

Recent News on our Competent Authorities

 

WOCCU/ENCU Applauds European Parliament Agreement on Digital Operational Resilience Act (DORA)

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WOCCU/ENCU Advocated Proportional Treatment Included for Credit Unions

The European Council presidency and the European Parliament reached a provisional agreement on the Digital Operational Resilience Act (DORA), which will overhaul regulations in the financial sector in Europe that sets uniform requirements for the security of network and information systems as well as critical third parties which provide ICT (Information Communication Technologies)- related services to them. This includes services such as cloud platforms and data analytics services.

The World Council of Credit Unions together with its partner the European Network of Credit Unions, and its members from Croatia, Estonia, Ireland, Netherlands, N. Macedonia, Poland, Romania, and Ukraine advocated for the proportional treatment of DORA regulations by urging the governing bodies to consider the size, nature, scale, and complexity of their services, activities, and operations. 

The provisional agreement embraces the WOCCU/ENCU proportionality approach in several ways but most importantly by allowing Member States to establish rules for those entities exempt under Article 2(5) of Directive 2013/36/EU (i.e., CRD IV exempt entities). 

“We thank the European Parliament for listening to our needs and tailoring rules that are appropriate for credit unions but also accomplish our mutual goal of protecting our members information from ICT breaches and ensuring the safe and sound operations of financial institutions”, said Andrew Price, WOCCU Sr. VP of Advocacy/General Counsel. WOCCU/ENCU further thank the many people instrumental in shaping this agreement including:

MEP Billy Kelleher (Ireland), MEP Mairead McGuinness (Ireland), the ENCU Member States (Croatia, Estonia, Ireland, Netherlands, N. Macedonia, Poland, Romania, and Ukraine) and the European Commission.

WOCCU/ENCU will continue to be engaged as the agreement obtains approval by the Council and the European Parliament before going through the formal adoption procedure.

Members of ENCU involved during this process include the following: representatives of the Irish League of Credit Unions (ILCU), National Association of Co-operative Savings and Credit Unions (NACSCU) of Poland, Federation of Romanian Credit Unions (FEDCAR), Estonian Union of Credit Cooperatives (EUCC), North Macedonia's FULM Savings House, and the Dutch Association of Cooperating Credit Unions (VSK).



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