2019 – IBFed

FATF guidance for the use of Digital ID

December 27, 2019July 24, 2020IBFed

The IBFed commented on the guidance proposed by the Financial Action Task Force (FATF), aimed at helping governments, financial institutions and other relevant entities to apply a risk-based approach to the use of digital ID for customer due diligence. In the letter we explain that consistency with global standards is important; financial entities should not be solely responsible for assessing the assurance level of the digital ID systems. We recommend to include reference to market resilience considerations and we advocate for a balance between the AML/CFT requirements and financial inclusion objectives. Finally, we would support inclusion of wider AML/CTF use cases than identification and authentication of natural persons. IBFed letter to… Read More

OECD Global Anti-Base Erosion Proposal under Pillar two

December 8, 2019July 24, 2020IBFed

The OECD published a “Global Anti-Base Erosion” set of rules aimed at avoiding profits to be shifted to jurisdictions where they are subject to no or very low taxation. In our response we state that banks are taxed in the appropriate jurisdictions based on where they have a regulated, taxable presence. Although we do not have any significant objections to the principles set out in the Pillar 2 consultation, we make 3 recommendations as we want to avoid unnecessary additional burden for banks. IBFed letter to OECD_Digital Taxation_2 December 2019

OECD Proposed Unified Approach under Pillar One

November 28, 2019July 24, 2020IBFed

The OECD published proposals for a “Unified Approach”, with a profit allocation for digitised businesses. Consistent with our previous exchanges and submissions we plead for a carve out of regulated banking services. IBFed letter to OECD_Digital Taxation_11 November 2019

The proposed amendments to the IFRS Foundation Due Process Handbook

July 25, 2019July 24, 2020IBFed

In our letter we comment upon the Effects Analysis IASB consultation regarding “IFRS exposure draft amending its Dues Process Handbook“. We believe our response to the IFRS exposure draft could set a benchmark for both IFRS and FASB as to how “Effects Analyses” should address bank-specific concerns. In addition, it includes a discussion related to expanding the IFRS Foundation’s standard due process to their “Agenda Decisions”, which are interpretations of existing standards. While subject to IASB approval, these Agenda Decisions can often change bank accounting practice and, therefore, should be subject to a robust review process. IBFed Comments IFRS Due Process Effects Analysis_25 July 2019

Addressing the Tax Challenges of the Digitisation of the Economy

March 10, 2019July 24, 2020IBFed

We welcome the opportunity to provide input as part of the OECD’s consultation set out in the public consultation document “Addressing the Tax Challenges of the Digitalisation of The Economy – 13 February – 6 March 2019”. Euro In our letters we refer to our paper dated 25 September 2018 setting out some of the concerns of the International Banking Federation (IBFed) in relation to the taxation of global banks, and how banks differ from highly digitalised businesses which featured as the primary focus of the OECD’s interim report in March 2018. We explain further how banks generally have a regulated / licences presence in the jurisdictions in which they operate… Read More

Revisions to Basel 3 and the treatment of securities financing transactions

January 12, 2019July 24, 2020IBFed

IBFed letter to BCBS on capital treatment of SFTs_11jan19 The IBFed appreciates the Basel Committee on Banking Supervision (BCBS) efforts to revise the Basel 3 standards. The International Banking Federation (IBFed) has submitted numerous letters to the BCBS discussing various Basel 3 revisions and making recommendations for practical, and objective-focused ways those standards can be adopted. We anticipate that as domestic jurisdictions begin adopting the latest round of finalized standards, issues that were not previously anticipated or fully appreciated will present themselves. This letter addresses one of these specific issues, the minimum haircut floors for Securities Financing Transactions (SFTs), about which we have not previously commented.