WOCCU urged the Basel Committee on Banking Supervision to emphasize that prudential regulators should consider proportionality when implementing Pillar 3 Disclosure Requirements in the Updated Framework so as to not subject less complex institutions with a lower risk profile to unnecessary disclosures.

These comments were made in WOCCU's recent comment letter on the Basel Committee's Consultative Document:  Pillar 3 Disclosure Requirements – Updated Framework.  WOCCU further supported finalization of the standard that limits the scope of most aspects this standard to “internationally active banks at the top consolidated levels”, which would in effect, exempt most credit unions from the most onerous aspects of the proposal.

A copy of the letter can be viewed here.