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