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IBFed Disclosure Task Force Comment Letter on Net Stable Funding Ratio

In their letter dated August 29, 2014, the Global Financial Markets Association (GFMA) and the Institute of International Finance (IIF) provided some additional information on the treatment of equities as a follow up to earlier comments they summited on the consultative document, Basel III: The Net Stable Funding Ratio. The International Banking Association (IBFed) also provided comments on this consultative document in our April 11, 2014 submission. read more


IBFed response on GLAC

The International Banking Federation1 (‘IBFed’) welcomes the role the Financial Stability Board (‘FSB’) is playing in coordinating the development of a proposal for Gone-concern Loss Absorbing Capacity (‘GLAC’) ahead of the November G20 Summit. The IBFed supports the objective set by the G20 Leaders of ensuring that systemically important institutions can be resolved in the event of failure without the need for taxpayer support and recognises the role of GLAC in this context. This letter sets out observations on this important topic drawn together from discussion with representatives of member associations and industry participants. read more


IBFed Newsletter - Summer 2014

On 20th and 21st May 2014, the 38th Board meeting was hosted in Washington by the American Bankers Association. The Board discussed the G20 work programme on financial regulation, tax and financial inclusion led by the Australian Presidency. The Board had the pleasure to meet and exchange views with senior US policy makers and regulators. read more


Final IBFed response to IASB on Conceptual Framework

The IBFed believes that the Conceptual Framework (CF) should be the primary conceptual source for development of any new requirements and guidance and also used as a tool by preparers in preparation of financial statements in the absence of a standard addressing a particular issue. While concepts in the Framework should be sufficiently detailed to be useful for the IASB as well as others such as the IFRS Interpretations Committee, the CF should remain principle based and refrain from addressing specific accounting issues which may be more appropriately addressed at a standards-setting level. read more


IBFed submission on Fundamental Review of the Trading Book (FRTB)

The International Banking Federation (IBFed) appreciates the opportunity to comment on the Basel Committee on Banking Supervision’s (BCBS) second consultative document on the Fundamental Review of the Trading Book (FRTB). The IBFed is supportive of this fundamental review and committed to ensuring that this review is as comprehensive and thorough as possible. We would like to express our general support for the alternative proposals prepared by the International Swaps and Derivatives Association (ISDA), the Institute of International Finance (IIF), and the Global Financial Markets Association (GFMA), that were submitted to the BCBS’s Trading Book Group (TBG) on January 19, 2014, and our general support for the joint ISDA/IIF/GFMA response submitted to the TBG today. read more


IBFed letter to to G20 Finance Ministers on Automatic Exchange of Information (AEOI)

The IBFed supports the development of an Automatic Exchange of Information (AEOI) regime as the means to achieve the policy objectives of the G20. We understand governments’ desire to implement an AEOI regime quickly. We believe that a consultative approach led by the Organisation for Economic Cooperation and Development (OECD) will be the most effective way to maximize the AEOI regime’s benefits and consider that the full benefits will not be realised without adequate consultation on the design and implementation of the AEOI regime. read more


G20 Regulatory Reform Programme

The members of the International Banking Federation (‘IBFed’) welcome the progress made towards the conclusion of the G20 regulatory reform programme. read more


IIF-IBFed June 2014 IRRCSR Letter

Please download and read the full letter... read more


IBFed letter to IOSCO on cross border regulation

The Financial Markets Working Group of the IBFed appreciates the opportunity to provide comments, at the request of IOSCO, regarding cross-border regulation. In general, we support IOSCO’s efforts to carry out the G20 mandate to improve global financial stability and promote transparency of the global securities markets, of which cross-border regulation is an integral part. We believe that successful cross-border regulatory approaches will focus on managing unreasonable and outsized risks, rather than trying to eliminate risk altogether. read more


IBFed Letter on OECD Discussion Draft on BEPS Action 2

The IBFed understands the importance of the Base Erosion and Profit Shifting (BEPS) project, and the OECD’s expectation that the final outcome will deliver fair, certain, predictable, sustainable and principled rules that taxpayers can easily apply and tax authorities can easily administer. read more


Letter to the FSB on Seventh Progress Report on Implementation of OTC Derivatives Market Reforms

The Financial Markets Working Group of the IBFed appreciates the opportunity to comment on the progress report (Report) published by the FSB on April 8, 2014. The Report, the seventh of FSB’s semi-annual progress reports, identifies and describes the progress made on the implementation of OTC derivatives market reforms. The Report also discusses areas in which further work is needed to complete the reforms and achieve the objectives laid out by the G20 commitments. FSB’s release of the Report comes at a critical juncture when most key international policy standards have been finalized and the remaining work is set to be completed by year-end. read more


BCBS Revised good practice principles for supervisory colleges

Please read the full letter... read more


IBFed response to Basel on Net Stable Funding Ratio

We appreciate the opportunity to review the consultative document, Basel III: The Net Stable Funding Ratio (NSFR), dated 12 January 2014. We welcome the clarification that the NSFR is not intended to be a one-year idiosyncratic stress test, but a structural liquidity ratio. read more


IBFed response to the second consultation on revisions to the Basel securitisation framework

The IBFed appreciates the opportunity to comment on the Basel Committee on Banking Supervision (the Committee) proposal to revise the Basel securitisation framework. We note that IBFed members will individually submit responses highlighting specific impacts to their respective securitisation markets, which we urge the Committee to take into full consideration when further developing its framework. read more


IBFed response on base erosion

The IBFed understands the desire of the G20 to address perceived ‘frictions’ and ‘weaknesses’ created by the interaction of different tax rules when applied to the cross-border activities of global businesses. We are committed to contributing constructively to the BEPS project, in the expectation that the final outcome will deliver fair, certain, predictable, sustainable and principled rules that taxpayers can easily apply and tax authorities can easily administer. read more


Joint IIF IBFed letter on Interest Rate Risk in the Banking Book

Please find below our joint letter to Mr Jakob Lund, Mr Toshio Tsuiki, Co-Chairs of Task Force on Interest Rate Risk in the Banking Book at the Basel Committee on Banking Supervision. read more


Comments on FSB consultation paper on Strengthening Oversight and Regulation of Shadow Banking

The IBFed welcomes the initiatives undertaken by the Financial Stability Board (FSB) to address the risk of parallel banking activities and the opportunity to contribute to the discussion on how to enhance transparency, strengthen regulation of security financing transactions, and improve market structure, regarding securities lending and repos. read more


IBFed comments on the Basel Committee’s Review of the Net Stable Funding Ratio

The IBFed appreciates the potential of the Net Stable Funding Ratio (NSFR) to contribute to enhancing the resilience of the banking sector, by limiting the risks associated with excessive maturity mismatches on banks’ balance sheets. read more


Response to BCBS on Capital Requirements for Banks’ Investments

We welcome the BCBS’s decision to review the prudential treatment of banks’ equity investments in funds by developing a revised capital regime and agree with the BCBS’s analysis of the ambiguities and shortcomings of the existing regime. We agree that there would be benefit in an explicit, clear and coherent approach to the treatment of capital requirements for equity investments in funds. read more


IBFed Newsletter - Summer 2013

On 20th and 21st May 2013, the 34th Board meeting was hosted in London by the British Bankers’ Association. The Board confirmed that Wim Mijs, CEO of the Dutch Banking Association and Chairman of the European Banking Federation’s Executive Committee, would be reappointed as IBFed chairman for a further period of two years. read more


Large Exposures Letter - June 28

The undersigned associations and our members appreciate the opportunity to comment on the BCBS consultative document on the Supervisory Framework for Measuring and Controlling Large Exposures. We support the BCBS’s goal of having a consistent large exposures (LE) framework for internationally-active banks across jurisdictions. In regard to the proposals contained in the consultative document, we have the following comments that we would like the BCBS, through the Large Exposures Group (LEG), to consider.

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Industry key messages arising from the meeting held on January 15th 2013 in Basel

The industry very much appreciated being given the opportunity to meet with the Large Exposures Group (LEG) on January 15th to discuss industry practices in managing single-name concentration risk. read more


IBFed Response to FED on Enhanced Prudential Standards and Early Remediation Requirements

The IBFed appreciates the opportunity to comment on the proposed rules (Proposal) published by the Board of Governors of the Federal Reserve System (the Board) that would implement the enhanced prudential standards required under Section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act or DFA) and the early remediation requirements required to be established under Section 166 DFA for foreign banking organisations (FBOs) and foreign nonbank financial companies supervised by the Board. read more


IBFed response to IASB Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9

The International Banking Federation (‘IBFed’) appreciates the opportunity to comment on the Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9 and would also like to express gratitude to the IASB staff for the extensive outreach undertaken during the consultation period. read more


IBFed comments on the EC’s proposal for a CD implementing enhanced cooperation in the area of FTT

The IBFed would like to express its strong opposition to the decision taken by the European Commission (EC) to allow its proposal for a financial transaction tax (FTT) to be pursued through the Enhanced Co-operation Procedure. We set out below our broad concerns over the FTT, while the Annex provides more detail on the potential impacts of the tax. read more


IASB FASB IBFed Letter on synchronisation of the deadlines on the Impairment Expos - 17/01/2013

The International Banking Federation (IBFed) continues to closely follow the IASB and FASB developments on the impairment project, and it is the intention of IBFed to provide both Boards with comments on their Exposure Drafts. The FASB issued its Exposure Draft (ED) on 20 December 2012, and the IASB ED is anticipated for issuance in February 2013. read more


Revised draft response to FSB CP on strengthening oversight and regulation - 17/01/2013

The different shadow banking documents of the FSB and IOSCO contain some overlaps and inconsistencies. The IBFed strongly suggests the integration of recommendations concerning money market funds (MMFs) and securitisation currently contained in the document of work stream 3 (Strengthening Oversight and Regulation of Shadow Banking Entities) in the policy recommendations of work streams 2 (on MMFs) and 4 (on securitisation) in order to develop a full impact assessment concerning these activities/entities. read more


IBFed Review Draft on General Hedge Accounting - 14/12/2012

As a follow up on the meeting which was held in London on 14 November 2012 between IASB Board and staff members (MM Cooper, Edelmann and Ms Lloyd) and the IBFed Accounting Working Group, we would like to provide you with written comments on the main concerns our members have on the review draft on general hedge accounting. read more


IBFed statement on the publication of the EDTF report on enhanced risk disclosures - 29/10/12

The IBFed has today made the following statement upon the publication of a report by the Enhanced Disclosure Task Force, set up under joint industry chairmen and with the support of the Financial Stability Board, on enhanced risk disclosures of banks: read more


IBFed response on Data Aggregation and Risk Reporting - 24/09/2012

The Global Financial Markets Association (GMFA), the Institute of International Finance (IIF), the International Banking Federation (IBFed), and The Clearing House Association L.L.C. (TCH - and together, Associations) are grateful for the opportunity to comment on the Basel Committee's consultative document on Principles for Effective Risk Data Aggregation and Risk Reporting (the Principles) read more


IBFed response to the BCBS consultation on monitoring indicators for intraday liquidity management

The IBFed welcomes the opportunity to share with the Basel Committee (BCBS) its views on the proposal for a framework on monitoring indicators for intraday liquidity management. We would like to offer several general observations and responses to the specific questions posed: read more


IBFed Newsletter - Summer 2012

In May IBFed attended a workshop held by the FSB to review the common data template for Global Systemically Important Banks (G-SIBs). In a letter sent to the FSB after the workshop, we expressed our concerns that Authorities may rush to seek and collect transaction information that is currently not available from the accounting information systems that banks maintain at parent level. We also urged that the various reporting initiatives at global, regional and national level be aligned. read more


IBFed Response to IOSCO Consultation on Global Developments in Securitization Regulation -07/08/2012

The IBFed agrees with the Consultation Report that securitisation of high-quality assets provides an important and stable source of alternative funding for banks and their customers and has the potential to be a robust risk transfer mechanism. read more


IBFed response to the BCBS consultation on: A framework for dealing with D-SIBs - 01/08/2012

The IBFed welcomes the opportunity to share with the Basel Committee on Banking Supervision (BCBS) its views on the proposal for a framework for dealing with domestic systemically important banks (D-SIBs). read more


IBFed Comments on Principles for the Regulation of Exchange Traded Funds - 16/07/2012

Against the background of the consultation paper prepared by IOSCO on “Principles for the Regulation of Exchange Traded Funds”, the IBFed highlights that there appears to be certain critical presumptions contained in the paper and certain assumptions underlying some of the principles which need to be fully evaluated to ensure that the policy response is not based on false premises. read more


Draft letter on the G-SIBs data template - 25/06/2012

The IBFED has much appreciated the opportunity to join the May 2 Workshop on the proposed Common Data Template (CDT) for Global Systemically Important Banks (G-SIBs). read more


IBFed Los Cabos G20 summit letter - 13/06/2012

I write on behalf of the members of the International Banking Federation (-IBFed') ahead of the meeting of G20 leaders in Los Cabos. read more


IBFed comments on IOSCO money market funds consultation

From a brief analysis of the consultation report, we note that the report appears to discuss the range of options that appeared in the U.S. President's Working Group Report on Money Market Fund Reforms. read more


Response to IOSCO on suitability requirements for the distribution of complex financial products

IBFed has joined with other trade associations to respond to proposals from IOSCO regarding suitability requirements for the distribution of complex financial products. read more


IBFed response to FSB report on repos and secured lending - 01/06/12

The IBFED appreciates the opportunity to comment on the FSB's Interim Report on Securities Lending and Repos: Market Overview and Financial Stability Issues. The IBFED supports the FSB's work on shadow banking and wishes to ensure a strong securities lending and repo market in the future. read more


Joint Trades Extraterritorial Legislation - Final Letter - 20/04/12

As you and your colleagues prepare to meet at the upcoming G20 Finance Ministers meeting in Washington, we now write to follow up on the 17 February letter submitted by the Global Financial Markets Association (GFMA) raising concerns about regulatory reforms that may be creating conditions resulting in a fragmented transatlantic capital market. read more


IBFed comments on supervision of financial conglomerates

IBFed has broadly welcomed the development of Basel Committee principles for the supervision of financial conglomerates. read more


IBFed in Brazil - 02/03/12

Last week IBFed Managing Director, Sally Scutt and Adam Cull visited Brazil to make contact with the Brazilian Federation of Banks and meet with officials and others. This note records the discussions. read more


IBFed welcomes new Financial Action Taskforce Guidance - 16/02/12

Updated measures from the Financial Action Task Force to help stamp out money laundering and terrorist financing were welcomed today by the International Banking Federation as a good step forward. read more


IBFed responds to IASB Agenda Consultation -30/11/11

IBFed has responded to the IASB's Agenda Consultation 2011. read more


IBFed responds to the FSB on a common template for G-SIBs - 14/11/11

IBFed has responded to the FSB Consultation entitled "Understanding Financial Linkages: A Common Data Template for Global Systemically Important Banks." read more


IBFed writes to G20 - 19/10/11

IBFed wrote to a number of senior figures ahead of the G20 summit to be held in Cannes in November. read more


IBFed responds to the FATF Fourth Round of Mutual Evaluations paper -20/09/11

IBFed has responded to the second public consultation from the Financial Action Task Force (FATF) on the Fourth Round of Mutual Evaluations. read more


Trade Association Letter on Legal Entity Identifier - 12/09/11

IBFed has joined fourteen trade associations in writing to the G20 Finance Ministers to update them on the industry's contribution to the global effort to develop a uniform and global legal entity identifier (LEI). read more


IBFed responds to FSB consultative document on effective resolution of SIFIs -05/09/11

IBFed has responded to the consultative document on the Effective Resolution of Systemically Important Financial Institutions, published by the Financial Stability Board (FSB). read more


IBFed responds to the OECD on consumer protection -31/08/11

IBFed has responded to draft High-level Principles on Financial Consumer Protection, published by the OECD. read more


IBFed responds to Basel consultative document on G-SIBs -26/08/11

IBFed has responded to the Basel Committee's Consultative Document "Global systemically important banks: Assessment methodology and the additional loss absorbency requirement". read more


IBFed responds to IFRS Foundation Trustees’ Strategy Review -09/08/11

IBFed has provided its views to the IFRS Foundation on the Trustees' Strategic Review. read more


High frequency trading -02/08/11

IBFed has given IOSCO its reflection on high frequency trading (HFT). read more


IBFed responds to CPSS-IOSCO consultative report on “Principles for FMIs” - 29/07/11

IBFed has responded to the CPSS-IOSCO consultative report from the perspective of participants in financial market infrastructures (FMIs). read more


IBFed responds to IOSCO on the role of securities regulators in systemic risk mitigation -15/07/11

IBFed has given IOSCO its reflection on their discussion paper "Mitigating Systemic Risk - A Role for Securities Regulators". read more


IBFed responds to the FSB on shadow banking -11/07/11

IBFed has responded to a background note on shadow banking, which was published by the Financial Stability Board (FSB). read more


IFRS Monitoring Board Consultative Report on the Governance Review - 11/05/11

IBFed has responded to an IFRS Monitoring Board Consultative Report on its Review of the governance of the IASB. In the response to the IFRS Foundation, IBFed commented on the importance of the governance framework to ensure that the IASB's standards meet broader policy imperatives and to ensure that due process is appropriately designed and followed in practice. Also, IBFed underlined the need for the conclusions of the Monitoring Board review to be consistent with the Trustees strategic review and vice versa. read more


IBFed Comments on FATF Project on Financial Inclusion - 20/4/11

The IBFed has responded to the FATF First Draft Guidance Paper on Financial Inclusion. In responding, IBFed expressed its support for the project that intended to help bring individuals and entities into the supervised and regulated financial system while simultaneously eliminating the need for a black market economy. IBFed also underlined the need for domestic authorities to take the final steps to adapt the FATF guidance to ensure individuals and entities are included in the financial system. IBFed will continue to work with FATF as the project moves forward. read more


Corporate bond markets in emerging markets - 18/04/11

IBFed has given IOSCO its reflections on corporate bond markets in emerging markets. In doing so, IBFed suggested policy makers focus on the following issues: (1) Deepening of ongoing legal and tax reforms and improvements in financial reporting and information disclosure standards to successfully enhance investors' protection and participation in the capital markets; (2) Further removal of obstacles to the participation of institutional investors in corporate bond markets and the promotion of the participation of retail investors in capital markets through local collective investment schemes; (3) Further deployment of actions to boost market demand in corporate bonds by means of “retailing” such investments, notably through investor education and institutional modernisation; and (4) Strengthening of property rights and policies which promote macroeconomic stability and stability of exchange rates. IBFed will continue to engage with the policy makers on this subject. read more


IBFed writes to FSB - 12/04/11

IBFed has written to the Financial Stability Board (FSB) setting out thoughts on the current status of the implementation of the G20 regulatory reform agenda. In the letter, IBFed offers support for the overarching objectives of the regulatory reform programme and the continuing efforts of the FSB to coordinate its implementation. We call for the FSA to prioritise work on those reforms most important for near-term financial stability. The letter also welcomes the FSB's efforts to promote consistent implementation of standards via its programme of peer reviews and thematic reviews, noting that level playing field is vital to prevent regulatory arbitrage. read more


IBFed writes to G7 on FATCA - 12/04/11

IBFed member associations wrote to their national tax authorities to ask that the US Foreign Account Tax Compliance Act be included on the agenda of G7 in April. In the letter, the members explained that whilst they understood the objective of FATCA, they were concerned about the difficulty of complying with a law which conflicts with domestic requirements. IBFed will be continuing to engage on this issue. read more


IBFed responds to Basel consultative document on Operational Risk - 12/04/11

IBFed has responded to consultative documents from the BCBS regarding operational risk: the Sound Practices for the Management and Supervision of Operational Risk, and Operational Risk – Supervisory Guidelines for the Advanced Measurement Approaches. In the response to the Sound Practices consultation, IBFed offered three recommendations to enhance the paper: (1) Include a specific supervisory expectation that financial regulatory agencies should take into account the nature, size, complexity and risk profile of a bank when evaluating its implementation of the operational risk principles; (2) Avoid process-driven board directives in the operational risk principles and do not require the board to take on roles that may detract and conflict with the board's strategic oversight responsibilities; and (3) Ensure that all principles included in the paper are risk-based and not prescriptive. In the letter commenting on the Supervisory Guidelines, IBFed welcomed the efforts of the Basel Committee's Standards Implementation Group to develop consistent practices for measurement of operational risk and provided technical contributions to enhance the utility of the guidelines. read more


Suitability Requirements for Market Intermediaries in Relation to Investors - 11/03/11

IBFed, The Institute of International Finance, and The Joint Associations Committee on Retail Structured Products ('the Associations') have jointly written to IOSCO on the Suitability Requirements for Market Intermediaries in Relation to Investors. read more


 
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