banner

IBFed Response on Consultation Paper - Guidelines on Prudential treatment of problem assets

The IBFed recognizes that the objective of the Basel Committee is to harmonize definitions of non-performing exposures and forbearance to ensure consistency of application, transparency, and the comparability of risk parameters amongst banks. read more


IBFed Response to the BCBS Consultation on Internal Models

The IBFed thanks you for the opportunity to provide comments on the BCBS’s consultative document, Reducing variation in credit risk-weighted assets – constraints on the use of internal model approaches (“consultative document”). read more


IBFed Comments on the Basel Committee on Banking Supervision’s Consultative Document: Pillar 3

In this letter, we provide overall comments on the proposal and highlight some key issues along with examples of our concerns. read more


IBFed Response on Standardised Measurement Approach for Operational Risk

The IBFed appreciates the opportunity to comment on the Basel Committee on Banking Supervision (BCBS) proposal for revisions to the operational risk capital framework. read more


IBFed Response to OECD Recommendations on BEPS

Please find attached the IBFed response to the OECD Recommendations on BEPS Actions: Aligning Transfer Pricing Outcomes with Value Creation. read more


IBFed Response on Foreign Account Compliance Tax Act (FATCA)

Over the recent months, the Internal Revenue Service (IRS) has continued to reach out to industry with its FATCA Roundtable and the follow up to that meeting. read more


IBFed response on the Phase I consultation Comment Letter

The International Banking Federation (IBFed) welcomes the opportunity to comment on the work of the Financial Stability Board Task Force that is considering issues of transparency related to climate-related risks. read more


IBFed Response on BRRD Article 55 - Contractual recognition of bail-in

The IBFed supports the Financial Stability Board’s (FSB) Key Attributes for Effective Resolution Regimes for Financial Institutions and regards the BRRD as generally a faithful implementation of these principles. We recognise that the requirements under Article 55 are intended to facilitate the cross-border recognition of resolution action, specifically bail-in. read more


IBFed Policy Paper on the OECD Recommendations Regarding Base Erosion and Profit Sharing

Please find attached the Policy Paper prepared by the IBFed Tax WG following our meeting with you in February 2016.  The memo explains why banks are different from other corporates and why/how these differences should be taken into account when rules are elaborated and recommendations are drafted regarding Base Erosion and Profit Shifting (BEPS), an area in which the OECD is playing a key role. read more


IIF IBFed Response to BCBS Step in risk Submission

The Institute of International Finance (“IIF”) and the International Banking Federation (“IBFed”)1 are pleased to provide comments on the Basel Committee’s (the “Committee” or “BCBS”) Consultative Document “Identification and measurement of step-in risk”, published December 17, 2015. read more


IBFed response to BCBS Standardised Approach for Credit Risk CP

The International Banking Federation (IBFed) is pleased to be able to provide its comments on the BCBS’s consultative document, Revisions to the Standardised Approach for credit risk2. In addition, we appreciated the opportunity to participate in the industry outreach session on February 17th that was organised by the Task Force on Standardised Approaches (TFSA). We welcomed being able to share the industry’s concerns with TFSA in more detail. read more


Final IBFed Response to Basel Consultation on TLAC Holdings

The International Banking Federation (IBFed) is supportive of the purposes of the FSB’s Total Loss Absorbing Capacity (TLAC) standard, to ensure that sufficient resources exist to safely resolve all covered banks, without impacting critical functions or using taxpayer funds. read more


IBFed Letter on Conceptual Framework for Financial Reporting

The IBFed is grateful for the opportunity to comment on the Exposure Draft (ED) ‘Conceptual Framework (CF) for the Financial Reporting’. We take the opportunity to express our support to the IASB to improve the framework as we consider the project very important for the whole standard setting process. read more


IBFed letter to FSB on G20

The members of IBFed have welcomed the focus of the Turkish G20 Presidency on the three ‘I’s: implementation, investment and inclusion and the role of the Financial Stability Board (‘FSB’) in delivering regulatory priorities to support these. Indeed, IBFed has sought to work constructively with the FSB and the other international standard setters to support the delivery of the G20 goals and shares the assessment of the FSB Chairman that considerable progress has been made towards the objective of building a more resilient and open global financial system. read more


Implementation Questions/Requests for Clarification on the Revised Pillar 3 Disclosure Standard

IBFed cover letter - Pillar 3 Further to a meeting that the British Bankers’ Association had with Mr. Alan Ball on July 2nd, we enclose implementation questions and requests for clarification on the BCBS standard Revised Pillar 3 disclosure requirements for your review and consideration. We would be pleased to discuss any questions that you may have. read more


Public Comment on International Regulatory Standards on Fees and Expenses of Investment Funds

The IBFed appreciates the opportunity to provide comments to the IOSCO consultation report entitled, Report on Elements of International Regulatory Standards on Fees and Expenses of Investment Funds (Report). We once again commend IOSCO for allowing ninety days to comment on the Report, which allows for the time necessary to review, analyze, and discuss the Report’s contents and to coordinate a substantive response. read more


BCBS Consultative Document on IRRBB

The Institute of International Finance (IIF), the International Banking Federation (IBFed), the Global Financial Markets Association (GFMA), and the International Swaps and Derivatives Association (ISDA), together “the Associations”, appreciate the opportunity to comment on the Basel Committee on Banking Supervision’s (BCBS) consultative document (CD) on Interest Rate Risk in the Banking Book (IRRBB). read more


International Banking Federation paper on BEPS

The regulation of international banks and their unique characteristics distinguishes them from multinationals operating in other industries, and means that they are not the natural focus of the OECD BEPS agenda. read more


Base Erosion and Profit Splitting – summary of activity and status of BEPS Actions

Please download the full summary via the link below read more


IBFed Newsletter - Summer 2015

On 27th and 28th May 2015, the 42nd Board meeting was hosted in Brussels by the European Banking Federation. The Board issued a communique following the meeting. This stressed the role of the banking industry in supporting growth and noted the need for continued industry participation in the Basel Committee’s work to promote simplicity and comparability in the calculation of risk weighted assets. read more


IBFed Response on Common Reporting Standard (CRS) for the automatic exchange of tax information

Thank you for meeting with the Tax Working Group of The International Banking Federation on 23 February 2015. At that meeting we discussed members’ concerns with the implementation timetable for the CRS. As agreed at the meeting, the purpose of this letter is to provide information in respect of the following: read more


IBFed Communique

The International Banking Federation Board (IBFed) agreed to press the Basel Committee to reconsider the economic impact of planned regulatory changes when it met in Brussels for its 42nd meeting on 27th and 28th May. read more


IBFed Letter on BC Guidance on Accounting for Expected Losses

Given its global application, the Guidance should be principle-based and open to various approaches that are consistent with the accounting standard. This concept underlies the majority of our comments. The accounting model should be built upon credit risk management practices and processes but it should not drive the risk processes itself. read more


IBFed Response to the Basel Committee on Net Stable Funding Ratio Disclosure Standards

The IBFed appreciates the opportunity to comment on the Basel Committee’s consultation document, Net Stable Funding Ratio Disclosure Standards. The proposed disclosure regime would require internationally active financial institutions to make public their Net Stable Funding Ratio (NSFR) and certain of its components through a common template. Similar to the Liquidity Coverage Ratio disclosure framework, the NSFR disclosure framework intends to improve the transparency of banking organizations’ liquidity positions and, by extension, strengthen market discipline. read more


IBFed Response on Derivatives Reform: Cross Border Regulatory and Recognition Issues Between US & EU

IBFed supports efforts of the United States (US) and European Union (EU) to regulate derivatives markets consistent with the G20’s goals of containing systemic risks and increasing the transparency of transactions in the global financial markets. We commend the US Commodity Futures Trading Commission (CFTC) and European Commission (EC) for establishing their respective regulatory frameworks for derivatives activity and for ongoing, good-faith efforts to reach mutual recognition of derivatives reform. read more


IBFed Comments on IOSCO report Entitled Task Force on Cross-Border Regulation

The Financial Markets Working Group of the IBFed appreciates the opportunity to provide comments to the IOSCO consultation report entitled, IOSCO Task Force on Cross-Border Regulation (Report). We commend IOSCO for allowing ninety days to comment on the Report, which allows for time necessary to review, analyze, and discuss the Report’s contents and to coordinate a substantive response. We believe this will facilitate meaningful discussions that will help lay the foundation for thoughtful and sensible cross-border standards, principles, or legal framework. read more


Capital Floors the design of a framework based on standardised approaches

The International Banking Federation (IBFed) appreciates this opportunity to comment on the Basel Committee on Banking Supervision’s (BCBS’s) proposal to revise the Basel standard on capital requirements, and share with you our views on the proposed framework for capital floors based on standardised approaches. read more


IBFed Revisions to the Standardised Approach for Credit Risk

The IBFed appreciates this opportunity to comment on the Basel Committee on Banking Supervision (BCBS) proposal to revise the Basel Committee’s standardised approach to credit risk and share with you our views. Before answering the Committee’s specific questions we provide some high level messages on the consultative document. read more


IBFed Response on Common Reporting Standard (CRS) for the automatic exchange of tax information

The principal purpose of our letter is to ensure that governments are aware of the challenges posed by the adoption of the CRS, not just for Financial Institutions (FIs) but the associated obligations for governments, particularly for those that have committed to early adoption (the Early Adopters group), to introduce the necessary regulatory frameworks and infrastructure to facilitate the implementation of CRS in their jurisdictions. read more


IBFed Response to BEPS Action 4 Discussion Draft: Interest Deductions and other Financial Payments

We welcome the opportunity to comment on the proposals in the Public Discussion Draft – BEPS Action 4: Interest Deductions and other Financial Payments (the Discussion Draft), and support the OECD’s consultative approach on the developments of these proposals. read more


Letter on adequacy of loss-absorbing capacity of globally systemically important banks in resolution

The International Banking Federation welcomes the opportunity to respond to the consultative document on the above topic. read more


IBFed response re BCBS Corporate Governance Initiative

The IBFed appreciates the opportunity to comment on the following Consultative Document issued by the Basel Committee on Banking Supervision in October 2014: Corporate governance principles for banks (the Consultative Document). read more


IBFed Response to the Consultation on Operational Risk - Revisions to the Simpler Approaches

We appreciate the opportunity to review the Basel Committee's consultative document, “Operational risk - Revisions to the simpler approaches”. We recognize the work of the Basel Committee to develop a new approach in order to streamline the framework and address weaknesses identified in the existing approaches. read more


IBFed Response on Revision of the Guidance for Sound Credit Risk Assessment and Valuation of Loans

The banking industry supports the objective to implement and maintain the impairment requirements of International Financial Reporting Standard 9 (IFRS 9) in a robust and consistent way both across similar portfolios within an institution as well as over time. read more


IBFed Response on Cross Border Recogntion of Resolution Action

The Financial Stability Board (‘FSB’) has played an important role in promoting the development of robust resolution regimes through the development of the Key Attributes and related initiatives. The recent progress report provided by the FSB to the G20 provides a useful summary of this work. read more


IIF WGCA: Joint Associations’ Letter to the TFIR re Comments on Proposed IRRBB/CSRBB QIS Templates

The Institute of International Finance (IIF), the International Banking Federation (IBFed), the Global Financial Markets Association (GFMA), the International Swaps and Derivatives Association (ISDA; and jointly, the Associations), and our members would like to thank the TFIR for the opportunity to discuss the proposed templates for the interest rate risk in the banking book (IRRBB) / credit spread risk in the banking book (CSRBB) quantitative impact study (QIS) at a meeting in London on November 11, 2014. We are hopeful to continue this constructive and useful dialogue as the TFIR continues its work in developing the IRRBB/CSRBB policy frameworks. read more


IBFed Response on Risk Mitigation Standards for Non-centrally Clear OTC Derivatives

The Financial Markets Working Group of the IBFed appreciates the opportunity to provide comments to the IOSCO consultation report (Consultation) regarding risk mitigation standards for non-centrally cleared OTC derivatives. 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 the risk mitigation standards are an integral part. Specifically, we support the goal of the risk mitigation standards that counterparties agree to fundamental economic and legal terms prior to, or contemporaneously with, the execution of a transaction, and to memorialize those terms. We further support the following intended benefits of the proposed risk mitigation standards: (i) the promotion of legal certainty and facilitation of timely dispute resolution; (ii) the facilitation of the management of counterparty credit and other risks; and (iii) increasing overall financial stability. read more


IBFed Comment Letter on the IASB Discussion Paper on Accounting for Dynamic Risk Management

The International Banking Federation (IBFed) is pleased to provide you with comment on the IASB discussion paper (DP) on accounting for dynamic risk management: a portfolio revaluation approach (PRA) to macro hedging. read more


ICANN Board Response to GAC Advice Regarding Financial gTLD Strings

The IBFed submits the following response to the 2 September 2014 communication that Dr. Stephen Crocker sent to the ICANN Governmental Advisory Committee (GAC) on behalf of ICANN’s New gTLD Program Committee (NGPC). Specifically, we are disappointed that the ICANN Board has yet again rejected GAC Advice on important consumer protection safeguards concerning financial gTLD strings, and respectfully request the NGPC reconsider its position and response to the GAC Advice in light of the following information. read more


IBFed Response on Shadow Banking

Shadow banking reform remains a top priority for the Financial Stability Board (FSB). In its February 2014 letter to the G20 members and their respective central banks (G20 Letter), the FSB refers to shadow banking as a “core element” of financial reform and highlights the G20 goal of “[t]ransforming shadow banking to transparent and resilient market-based financing.” IBFed believes that shadow banking reform and regulation is essential for the proper functioning of the global financial markets. We agree with FSB’s statement that “continued support of G20 finance ministers and central bank governors will be critical to ensure that we don’t just fix past fault lines but build a system that can evolve with the global economy to support strong, sustainable and balanced growth across the G20.” read more


IBFed Response on Pillar 3

Thank you for the opportunity to comment on the Basel Committee on Banking Supervision’s (BCBS) consultative document: Review of the Pillar 3 disclosure requirements (“consultative document”). At the outset, the IBFed and its member associations wish to express appreciation for the openness of the BCBS to engage in dialogue on changes to Pillar 3 disclosures with the bank, analyst and investor communities. The industry outreach meeting on September 19th provided an opportunity for the banking industry stakeholders to express themselves directly on our key concerns. This submission will document the considerations that we hope you will find relevant as you work to finalize guidance on Pillar 3 disclosures. read more


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


Task Force on IRRBB (TFIR)

Please find attached two papers discussing the IIF and IBFed (the Associations) positions and recommendations on the possible regulatory framework for interest rate risk in the banking book (IRRBB) and credit spread risk in the banking book (CSRBB). read more


IIF WGCA: Transmittal Letter to BCBS Chairman on TFIR - Fatal Flaws

Thank you very much for giving us the opportunity to meet again with the Task Force on Interest Rate Risk in the Banking Book (TFIR) on July 7th to discuss technical issues relating to the TFIR’s work of developing policy options for interest rate risk in the banking book (IRRBB) and credit spread risk in the banking book (CSRBB). We really appreciate the consultative approach that the TFIR has taken, and we hope to continue this constructive dialogue throughout the policy development process. 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.

read more


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


 
IBFED would like to place cookies on your computer to help us make this website better. By continuing to use the site you are agreeing to our use of cookies.
To find out more about the use of cookies, please see our privacy policy