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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

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

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  

Document on Tax Policy Design for Banks that can be used by IBFED members for in country discussions, as appropriate. The document reflects the view on appropriate tax policy design for global banks, commenting upon the OECD Tax Policy Principles applicable for banks. We argue that tax policy should not discriminate between taxpayers, or industry groups (eg bank levies or surcharges and that banks should not automatically be seen a collection mechanisms). It will be shared with the OECD during our upcoming meetings in March 2018. Tax Policy and Design for Banks_30 January 2018

The IBFed appreciates the opportunity to provide comments on the Consultative Document. At this time, we support each jurisdiction’s own bank supervisory agencies in their efforts to address the challenges and opportunities related to emerging fintech technologies while continuing to encourage comparably equivalent national regulatory approaches. Bank supervisors have the authority to supervise banks. Developing an international fintech regulatory framework may have its merits in certain circumstances, as is demonstrated by FATF for example, but could be premature regarding the fast-changing digital environment and because most bank supervisors don’t have the authority to provide this oversight within their own jurisdiction let alone across borders. IBFED Response to BCBS on, 31 Oct… Read More