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 Fundsâ€, 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