IBFED Response to the BCBS consultation on Pillar 3 (3rd phase of the review)

The IBFED supports the aim of transparency that should be accomplished by means of Pillar 3 disclosures requirements. However, we have concerns with the proposed disclosure of certain sensitive or proprietary information in phase three. At the same time, we emphasize that the focus must be on disclosures that are relevant for users. The proposed amount of information to be disclosed increases the risk of misinformation and reduces comparability. This would be counterproductive. Examples to illustrate these concerns are provided below. IBFED Letter_25 May IBFed Pillar 3_final  

Continue Reading

IBFED Response to the draft FATF paper on « Vulnerabilities linked to the concealment of beneficial ownership »

In our response we acknowledge the importance of the FATF document as it contains numerous case studies whereby specific structures are abused to conceal the beneficial owners. We further point out that there is a widening gap between the obligations applicable to financial intermediaries and those applicable to other professions. Hence we want to avoid new requirements and recommendations for financial intermediaries. And we also mention that digital solutions supported by government agencies or official authorities are probably more efficient. IBFED Response to FATF_5 April 2018_Beneficial Ownership        

Continue Reading

Intra-group Funding by Global Banks

Paper on pricing related party debt for banks that will be shared with the OECD in March 2018. We discuss the issue of intra-group lending which can be significant for global banks. They must adhere to arm’s length principles when conducting such intra-group lending. We argue that there needs to be flexibility to determine the arm’s length price. The Revenue Authorities should accept a number of different alternative approaches, including using external issuances or pricing from an internal mechanism (such as a yield curve). IntraGroup lending_30 January 2018

Continue Reading