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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
Basel Committee Discussion Paper on Digital Fraud February 16, 2024
Basel Committee Disclosure Framework for Climate-Related Financial Risk February 29, 2024
Basel Committee Recalibration of Shocks for Interest Rate Risk in the Banking Book March 28, 2024
 

Recent News on our Competent Authorities

 

Financial Stability Board Cyber Incident Reporting includes WOCCU Recommendations

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Financial Stability Board

The Financial Stability Board issued its report setting out 16 recommendations to address these issues with a view to promote best practices in cyber incident reporting. Included in the Recommendations to Achieve Greater Convergence in Cyber Incident Reporting, were several recommendations made by World Council including proportionality language to help smaller community based financial institutions and language surrounding feedback loops to assist credit unions in defending themselves against cyber-attacks.

The report draws from the FSB’s body of work on cyber, including engagement with external stakeholders, the report identifies commonalities and details practical issues associated with the collection of cyber incident information from FIs and the onward sharing between financial authorities. These practical issues include:

  1. operational challenges arising from the process of reporting to multiple authorities;
  2. setting appropriate and consistent qualitative and quantitative criteria/thresholds for reporting;
  • establishing an appropriate culture to report incidents in a timely manner;
  1. inconsistent definitions and taxonomy related to cyber security;
  2. establishing a secure mechanism to communicate on cyber incidents; and
  3. legal or confidentiality constraints in sharing information with authorities across borders and sectors.

A copy of the report can be viewed here.

 



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