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	Risk-Based Guidance on Recommendation 25 (Beneficial Ownership and Transparency of Legal Arrangements)	December 8, 2023
Committee on Payments and Market Infrastructures (Bank for Int'l Settlements)	Linking Fast Payment Systems Across Borders: Considerations for Governance and Oversight	December 13, 2023
European Commission	Critical ICT Third-Party Service Providers - Criteria & Fees	December 14, 2023
Basel Committee	Disclosure of Banks' Cryptoasset Exposures	January 31, 2024
Basel Committee	Discussion Paper on Digital Fraud	February 16, 2024
Basel Committee	Disclosure Framework for Climate-Related Financial Risk	February 29, 2024

Recent News on our Competent Authorities

2023-10-13

World Council Urges Basel Committee to Limit Regulatory Burden on Credit Unions

World Council submitted a comment letter last week on the Basel Committee’s proposed updates to the Core Principles for Effective Banking Supervision (Core Principles). The Core Principles are global standards for prudential regulation and supervision. Supervisory authorities across the globe use the Core Principles as a benchmark for evaluating the effectiveness of their regulatory and supervisory frameworks. This is the first formal update to the Core Principles since 2012.

Tags
Comment Letter, Basel

World Council Urges Basel Committee to Limit Regulatory Burden on Credit Unions

2021-01-05

World Council Comments on IASB Discussion Paper on Business Combinations

The International Accounting Standards Board requested comment on their Discussion Paper regarding Business Combinations – Disclosures, Goodwill and Impairment. World Council supported the adoption of the scheduled goodwill amortization as well as simplifications offered for the impairment test, but urged the disclosure of scheduled goodwill amortization as a separate item outside of the operating result. World Council expressed concern that this disclosure would “require the disclosure of internal confidential information that, if disclosed, could operate to the detriment of a company.”

Tags
Comment Letter, International Accounting Standards Board

World Council Comments on IASB Discussion Paper on Business Combinations

2021-01-05

World Council Responds to IFRS Foundation’s Consultation Paper on Sustainability Reporting

In September 2020, the International Accounting Standards Board requested stakeholders to respond to the IFRS Foundation’s questions on sustainability reporting found in their Consultation Paper on Sustainability Reporting. The consultation paper hoped to address concerns surrounding consistency and comparability in sustainability reporting. According to the IFRS, “A set of comparable and consistent standards will allow businesses to build public trust through greater transparency of their sustainability initiatives, which will be helpful to investors and an even broader audience in a context in which society is demanding initiatives to combat climate change.”

Tags
Comment Letter, International Accounting Standards Board

World Council Responds to IFRS Foundation’s Consultation Paper on Sustainability Reporting

2020-10-01

WOCCU Urges Proportionality for FSB’s Evaluation of Too-Big-to-Fail Reforms

The Financial Stability Board (FSB), requested comment on their Consultation Report on the Evaluation of the effects of too-big-to-fail (TBTF) reforms for systemically important banks. The reforms under evaluation included, “ (i) standards for additional loss absorbency through capital surcharges and total loss-absorbing capacity requirements; (ii) recommendations for enhanced supervision and heightened supervisory expectations; and (iii) policies to put in place effective resolution regimes and resolution planning to improve the resolvability of banks.” Although TBTF reforms were constructed for systemically important banks, WOCCU emphasized that these reforms have indirectly affected credit unions due over regulation by national level regulators that uses TBTF reforms as a standard across all financial institutions regardless of the size, risk, and complexity of the institution. WOCCU’s response to the FSB’s Consultation Report can be found here.

Tags
Comment Letter, Financial Stability Board

WOCCU Urges Proportionality for FSB’s Evaluation of Too-Big-to-Fail Reforms

2020-09-22

ENCU Urges EBA to Address De-risking

The European Banking Authority (EBA) called for input to understand the impact of de-risking on financial institutions and customers. The European Network of Credit Unions responded to the EBA’s directed questions and highlighted that credit unions are often the subject of de-risking by banks. Reasons for this include perceived regulatory burden and risks associated with AML/CFT requirements and the potential to eat into profits; confusion surrounding responsibility associated with AML/CFT requirements; and conflicting privacy standards in various countries creating difficulty navigating cross-border operations. ENCU noted that de-risking has reduced access to bank services causing credit unions to seek these services from second and third tier banks, which in turn has proven to be costly and burdensome, and therefore a deterrent to the provision of these services to its members.

Tags
Comment Letter, European Banking Authority

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