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

2023-11-28

FSB Report on Multifunction Crypto-Asset Intermediaries

The Financial Stability Board (FSB) recently published a report on the financial stability implications of multifunction crypto-asset intermediaries (MCIs). MCIs are individual firms or groups of affiliated firms that provide crypto-asset services, products and functions usually around a trading platform. In many cases MCI vulnerabilities are similar to those of traditional finance. However, these vulnerabilities can be amplified by limited controls and operational transparency. MCI vulnerabilities could impact traditional financial systems through transmission channels.

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Financial Stability Board

FSB Report on Multifunction Crypto-Asset Intermediaries

2023-10-20

Climate-Related Disclosure and Monitoring Grows

The Financial Stability Board (FSB) has published its annual progress report on climate-related disclosures. The report indicates further development regarding climate disclosures over the last year. International regulatory bodies are focused on creating comparable public disclosures of climate-related financial risks to use in the analysis of vulnerabilities in the financial system.

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Financial Stability Board

Climate-Related Disclosure and Monitoring Grows

2023-09-26

FSB identifies frictions from data frameworks that pose challenges to enhancing cross-border payments

The Financial Stability Board (FSB) published its stocktake of international data standards relevant to cross-border payments. The stocktake looks at national and regional data frameworks relevant to the functioning, regulation and supervision of cross-border payment arrangements. It takes forward one of the priority actions under the G20 Cross-border Payments Roadmap, to enhance the interaction between data frameworks and cross-border payments. The report:

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Financial Stability Board

FSB identifies frictions from data frameworks that pose challenges to enhancing cross-border payments

2023-09-05

FSB Chair writes to G20 Leaders ahead of the New Delhi Summit

The Financial Stability Board (FSB) today published two letters from its Chair, Klaas Knot, to G20 Leaders ahead of their Summit in New Delhi on 9-10 September, noting the following key points:

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Financial Stability Board

FSB Chair writes to G20 Leaders ahead of the New Delhi Summit

2023-07-13

FSB Publishes Annual Progress Report on Roadmap Addressing Climate-Related Financial Risks

On July 13, 2023, in response to the finalization of the International Sustainability Standards Board's (ISSB) global sustainability disclosure standards, the Financial Stability Board released its annual progress report on the FSB Roadmap for Addressing Climate-Related Financial Risks, which outlines advancements achieved in support of the roadmap that were made not only by the FSB, but also standard-setting bodies and other international organizations. The progress report further highlights areas that need additional consideration, as well as updates on Roadmap action items. On July 17-18 in a meeting in Gandhinagar, India, the progress report will be delivered to the G20 Finance Ministers and Central Bank Governors for review.

The FSB has made it clear it is in support of the ISSB's final standards. Finalization has prompted a handover in the responsibility to monitor progress made with firm disclosures. Monitoring responsibilities will shift from the Task Force on Climate-Related Financial Disclosures (TCFD), which was created by the FSB to develop recommendations on effective disclosures, to the ISSB in 2024. According to the FSB, there is progress in all four blocks of the Roadmap, including firm-level disclosures, data, vulnerabilities analysis, and regulatory and supervisory practices and tools.

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Financial Stability Board

FSB Publishes Annual Progress Report on Roadmap Addressing Climate-Related Financial Risks

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