The Clearing House (TCH) and the ABA have filed a comment letter on the BCBS’s consultative document proposing a consolidated and enhanced framework with respect to Pillar 3 disclosure requirements. In the letter, the Associations agree that robust Pillar 3 disclosure requirements are appropriate and necessary, but they identify several concerns with the proposed enhancements, notably: (i) elements of the proposal related to regulatory requirements that are not yet finalized should be deferred until such requirements are finalized; (ii) the tables and templates should be revised to avoid requiring disclosure of proprietary and market-sensitive information; (iii) the BCBS should explicitly provide national supervisory discretion for implementation of pillar 3 disclosure requirements; (iv) the BCBS should provide the opportunity for comments on a holistic basis; and (v) signposting should be supported where appropriate to avoid confusing, duplicative public reports.
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