The International Banking Federation follows up on its previous submissions and comments on Pillar 2, with regard to both the Blueprint document and subsequent statements by the OECD. Further comments are provided on the regulatory capital instruments and adverse outcomes that could arise for Additional Tier 1 (AT1) Capital under the proposed Global anti-Base Erosion (GLoBE) rules in Pillar 2.  IBFed to OECD_Pillar 2_23 Nov 2021