TCH and ABA File Letter to BCBS on Its Pillar 3 Disclosure Requirements Proposal

TCH and ABA File Letter to BCBS on Its Pillar 3 Disclosure Requirements Proposal

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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The views expressed do not necessarily reflect those of the Bank Policy Institute’s member banks, and are not intended to be, and should not be construed as, legal advice of any kind.