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  

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Tax Policy Design for Banks

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

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IBFED Response to the BCBS Consultation on Fintech

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

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