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.
You Might Also Be Interested In...
Regulatory Reporting and Accounting BPI Comments on Banking Agencies’ Proposed Revisions to Call Reports and FR Y-9
Regulatory Reporting and Accounting BPI Comments on CFPB’s Proposed Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders
Regulatory Reporting and Accounting BPI Responds to NYDFS Request for Comments Concerning Presumption of Control of NY-Charted or Licensed Institutions
Security BPI and SIFMA Respond to NYDFS Proposal on Cybersecurity Requirements for Financial Services Companies
Cybersecurity Financial Trades Call for Accessible, Functional and Simple Cyber Incident Reporting Rules
More Posts by This Author
Silicon Valley Bank BPI’s Jeremy Newell Testifies on SVB Supervision Before House Oversight Committee
Bank Activities and Structure The Importance of Regional Banks for Small Business Lending and Economic Growth