WOCCU urged the Basel Committee to adopt a proportional regulatory approach in its recent comment letter on the Basel Committee on Banking Supervision's Technical Amendment: Pillar 3 Disclosure Requirements – Regulatory Treatment of Accounting Provisions.
Specifically with the accounting for the credit quality of assets, WOCCU urged limiting reporting burdens for non-complex, community-based financial institutions by not allowing country-level disclosures for the geographic breakdown required under the disclosure. This would reduce the compliance burden on most credit unions.
Further, WOCCU urged omitting Total Loss-Absorbing Capacity (TLAC)-related measures from a credit union's Pillar 3 disclosures for a credit union that is not required to issue TLAC instruments.
A copy of the letter can be found here.