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FSB and Basel Committee Move to Transition Away from LIBOR by End of 2021

The Financial Stability Board (FSB) and Basel Committee on Banking Supervision (BCBS) published a report entitled, Supervisory issues associated with benchmark transition: Report to G20, which outlines supervisory recommendations LIBOR transition. The report concludes that, “Continued reliance of global financial markets on LIBOR poses clear risks to global financial stability. Transition away from LIBOR by end-2021 requires significant commitment and sustained effort from both financial and non-financial institutions (FIs and non-FIs) across many jurisdictions.” The report also includes surveys initiated by the FSB, the BCBS and the International Association of Insurance Supervisors (IAIS), developed to address remaining challenges to the benchmark transition.

The report outlined three recommendations that support LIBOR transition in jurisdictions with LIBOR exposures:

  • Identification of transition risks and challenges – authorities and standard-setting bodies to issue public statements to promote awareness and engage with trade associations, and authorities to undertake regular surveys of LIBOR exposure and to request updates from financial institutions.
  • Facilitation of LIBOR transition – authorities to establish a formal transition strategy supported by adequate resources and industry dialogue. Supervisory authorities should consider increasing the intensity of supervisory actions when the preparatory work of individual banks is unsatisfactory.
  • Coordination – authorities to promote industry-wide coordination, maintain dialogue on the adoption of fallback language, consider identifying legislative solutions, where necessary, and exchange information on best practices and challenges. The FSB and the standard-setting bodies will coordinate at the international level to identify key common metrics for monitoring transition progress.”

More information on the BSB and BCBS’ LIBOR transition report can be found here and here.

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Basel, Financial Stability Board

FSB Consults on Too-Big-To-Fail Refomrs

The Financial Stability Board issues a consultation on the evaluation of the effects of too-big-to-fail (TBTF) reforms fro systemically important banks.  The evaluation's main findings are as follows:

  • TBTF reforms have made banks more resilient and resolvable;
  • The benefits of the reforms significantly outweigh the costs; and
  • There are still gaps that need to be addressed.

The reforms being evaluated include: (i) standards for additional loss absorbency through capital surcharges and total loss-absorbing capacity requirements; (ii) recommendations for enhanced supervision and heightened supervisory expectations; and (iii) policies to put in place effective resolution regimes and resolution planning to improve the resolvability of banks.

A copy of the consultation can be viewed here.

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Financial Stability Board

FSB Publishes Consultation Report on Cyber Incident Response and Recovery

The Financial Stability Board (FSB) provided their consultation report,  Effective Practices for Cyber Incident Response and Recovery, to the G20 Finance Ministers and Central Bank Governors for their April 15th virtual meeting. The report is a toolkit of 46 effective practices to address “cyber incident response and recovery activities”.

According to the FSB report, the effective practices consist of seven of the following components:

  1. Governance - frames how cyber incident and recovery is organised and managed.
  2. Preparation – to establish and maintain capabilities to respond to cyber incidents, and to restore critical functions, processes, activities, systems and data affected by cyber incidents to normal operations.
  3. Analysis – to ensure effective response and recovery activities, including forensic analysis, and to determine the severity, impact and root cause of the cyber incident to drive appropriate response and recovery activities.
  4. Mitigation – to prevent the aggravation of the situation and eradicates cyber threats in a timely manner to alleviate their impact on business operations and services.
  5. Restoration – to repair and restore systems or assets affected by a cyber incident to safely resume business-as-usual delivery of impacted services.
  6. Improvement – to establish processes to improve response and recovery capabilities through lessons learnt from past cyber incidents and from proactive tools, such as tabletop exercises, tests and drills.
  7. Coordination and communication – to coordinate with stakeholders to maintain good cyber situational awareness and enhances the cyber resilience of the ecosystem.

For more information on the FSB press release, visit their website here.

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Financial Stability Board

FSB Delivers Covid-19 Regulatory Principles to G20


The Financial Stability Board delivered a report setting out the financial stability implications of COVID-19 and policy measures taken to address them to the G20 Finance Ministeres and Central Bank Governors. 

The report sets out five principles that underpin the official community’s rapid and coordinated response to support the real economy, maintain financial stability and minimize the risk of market fragmentation. Using these principles, authorities will:

  • Monitor and share information on a timely basis to assess and address financial stability risks from COVID-19;
  • Recognize and use the flexibility built into existing financial standards to support our response; seek opportunities to temporarily reduce operational burdens on firms and authorities;
  • Act consistently with international standards, and not roll back reforms or compromise the underlying objectives of existing international standards; and
  • Coordinate on the future timely unwinding of the temporary measures taken.
A copy of the report can be viewed here
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Financial Stability Board

FSB Encouraging Flexibility in COVID-19 Response

The Financial Stablity Board (FSB) is encouraging authorities and financial institutions to make use of the flexibility within existing international standards to provide continued access to funding for market participants and for businesses and households facing temporary difficulties from COVID-19, and to ensure that capital and liquidity resources in the financial system are available where they are needed.

The FSB notes that many authorities have already taken action to release available capital and liquidity buffers, in addition to actions to support market functioning and accommodate business continuity plans.

WOCCU continues to urge flexibility by regulators to keep credit union operations functioning and able to finance the needs of their members.

A copy of the FSB release can be viewed here, and WOCCU's recommendations for purdential regulators can be viewed here

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Financial Stability Board

FCA Responds to ISDA with Letter on Non-Representative LIBOR

In December 2019, the International Swaps and Derivatives Association (ISDA) responded to a November 2019 letter from the Financial Stability Board’s (FSB) Official Sector Steering Group (OSSG) asking the ISDA to add a pre-cessation trigger in company with the cessation trigger as standard language in the definitions for new derivatives. The OSSG believes “[t]his would help to reduce systemic risk and market fragmentation by ensuring that as much of the swaps market as possible falls back to alternative rates in a coordinated fashion.” The ISDA requested a statement from the Financial Conduct Authority (FCA), and the ICE Benchmark Administration stating “ that the “reasonable period” during which a “non-representative” LIBOR would be published would be minimal (i.e., a number of months not years) after the FCA announces that LIBOR is no longer representative.”

The letter from FCA responding to ISDA’s request included reference to relevant laws and how FCA “intends to apply them”. The FCA’s letter also clarified that its, “preference is for an orderly cessation of LIBOR in which its discontinuation is pre-announced, market participants have prepared for this, and publication of a non-representative LIBOR is avoided.” The FCA’s response to the ISDA can be found here. More information regarding the chronicle of events surrounding group responses regarding the pre-cessation trigger can be found here.

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Financial Stability Board

WOCCU Urges Further Proportionality to FSB in Too Big to Fail Evaluation

WOCCU urged the Financial Stability Board (FSB) to consider issuing clearer guidance on factors that should be considered by national level regulators when developing proportionate approaches to the numerous standards adopted since the financial crisis, many of which are targeted to the "Too-Big-To-Fail" institutions.  

WOCCU noted that the complexity, usefulness, and corresponding regulatory burden and costs for smaller non-systemically important credit unions often becomes questionable, particularly those that are only involved in deposit taking and simple retail consumer lending.  While many of the Too Big to Fail Reforms were necessary, the application to credit unions and other mutuals needs to be appropriately and proportionately tailored.

The comments came as part of the FSB's Evaluation of the Too-Big-To-Fail Reforms.

A copy of the letter can be viewed here.
 

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Comment Letter, Financial Stability Board

FSB Issues Reports on Correspondent Banking

The Financial Stability Board (FSB), published two reports outlining its progress on its plan to assess and address the decline in correspondent banking relationships and or remittances service providers' access to banking service.  Notably the report notes that the decline in the number of correspondent banking relationships remains a source of concern for the international community, as the number of active correspondent banks declined by 3.4% in 2018, bringing the cumulative decline since 2011 to 19.3%. Concentration increased, as fewer correspondent banks are handling payments.

Access to correspondent banking relationships remains a critical issue in some regions and jurisdictions. WOCCU has consistently urged the continuation of efforts to reduce "de-risking" in the financial system which often creates obstacles for low risk credit unions trying to establish correspondent bank accounts or clear checks.

The FSB reports can be viewed here.

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Financial Stability Board

FSB Launces Evaluation of Too-Big-To-Fail Reforms

The Financial Stability Board (FSB) announced it is seeking feedback from as part of its evaluation of the effects of the "Too-Big-To-Fail" reforms for banks that were agreed by the G20 in the aftermath of the global financial crisis. The evaluation will assess whether the implemented reforms are reducing the systemic and moral hazard risks associated with systemically important banks and the broader effects of the reforms on the overall functioning of the financial system.  

Further information on the evaluation can be viewed here.

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Financial Stability Board

WOCCU Urges Further Proportionality to FSB to Increase SME Lending

WOCCU urged the Financial Stability Board (FSB) to continue with proportionality efforts in light of the voluminous regulatory reforms adopted since the financial crisis.  WOCCU noted that the additional complexity often filters down disproportionately to smaller, less complex institutions such as credit unions and other community based cooperative institutions.  WOCCU commented that these regulations need to be proportionately tailored and noted that the effects can have significant impact in their ability to lend to SMEs. 

These comments came as part of the FSB’s request for Feedback on the Effects of Financial Regulatory Reforms on SME Financing where they are evaluating how the regulatory reforms have affected SME lending.

A copy of the letter can be viewed here.

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Comment Letter, Financial Stability Board

Report on Incentives to Centrally Clear OTC Derivatives Reflects WOCCU Concerns

The Financial Stability Board (FSB), the Basel Committee on Banking Supervision (BCBS), the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) published their final report on Incentives to centrally clear over-the-counter (OTC) derivatives which includes provisions addressing issues raised by WOCCU in its comment letter

The report issued today notes that incentives available for larger firms were not always in place for other types of firms including credit unions and that this report c ould be used as a basis for possible fine-tuning some of the post-crisis regulatory reforms. 

The central clearing of standardised OTC derivatives is a pillar of the G20 Leaders' commitment to reform OTC derivatives markets in response to the global financial crisis and this report evaluates how these reforms interact and how they could affect incentives.

WOCCU will continue to monitor this report to ensure that access for credit unions and other community based-financial institutions are treated fairly and proportional.

A copy of the final report can be viewed here.

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Financial Stability Board

Cyber Lexicon Includes WOCCU Recommended Changes

The Financial Stability Board (FSB) published a Cyber Lexicon intended to support the work of the FSB, standard-setting bodies, authorities and private sector participants to address financial sector cyber resilience. 

WOCCU recently supported the initiative to develop a Cyber Lexicon to address cyber security and cyber resilience in the financial sector, but made numerous suggestions, many of which were included in today’s issuance.  Of note was the WOCCU recommended approach taken by the FSB to focus the scope of the lexicon on core terms and exclude overly technical terms as well as general business and regulatory terms to avoid confusion among industries.

The lexicon as adopted can prove to be useful to support work in the following areas:

  • Cross-sector common understanding of relevant cyber security and cyber resilience terminology;
  • Work to assess and monitor financial stability risks of cyber risk scenarios;
  • Information sharing as appropriate; and
  • Work by the FSB and/or standard-setting bodies to provide guidance related to cyber security and cyber resilience, including identifying effective practices.

The lexicon will be delivered to the G20 Leaders’ Summit in Buenos Aires later this month and can be viewed here.

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Financial Stability Board

WOCCU Urges Flexibility by FSB for Legal Entity Identifier

WOCCU urged the Financial Stability Board to incentivize increased uptake of the Legal Entity Identifier rather than to mandate its usage.  This approach will limit unreasonable regulatory burdens on credit unions and other community-based financial institutions as the expense of such adoption outweighs the benefit of mandatory adoption.  WOCCU acknowledged the benefits of optional adoption that can result from the use of LEI in areas such as AML/CFT and other areas,but did not support mandatory adoption for smaller institutions.

These comments came as part of the FSB's Thematic peer review on implementation of the Leal Entity Identifier:  summary Terms of Reference.


A copy of WOCCU's letter can be viewed here.

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Comment Letter, Financial Stability Board

WOCCU Urges Continued Credit Union Access to Central Clearing of OTC Derivatives.

WOCCU made numerous recommendations that will allow credit unions to continue to have access to central clearing of over-the-counter derivatives.  In particular WOCCU urged a reduction in Basel III’s capital requirements for issuers and clearers of interest-rate swaps and caps to help better ensure continued access to interest rate derivatives for credit unions.  Without changes to these rules, the banks’ cost of capital for issuing or clearing interest rate derivatives may result in the banks dropping credit unions and other smaller derivatives users as clients.

The comments were filed in response to the Financial Stability Board (FSB), the Basel Committee on Banking Supervision (BCBS), the Committee on Payments and Market Infrastructure (CPMI) and the International Organization of Securities Commissions’ (together “the Committees”) Consultative Document: Incentives to centreally clear over-the-counter (OTC) derivatives.

A copy of the letter can be viewed here.

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Basel, Comment Letter, Financial Stability Board

WOCCU Urges Proportionality in FSB's Cyber Lexicon Initiative

The World Council of Credit Unions urged the Financial Stability Board (FSB) to take a proportional regulatory approach in its cybersecurity guidance so as to not impose an unreasonable compliance burden on community-based financial institutions, such as credit unions.  These comments came as part of World Council's comments on FSB's Consultative Document on Cyber Lexicon.

World Council supported FSB's initiative to develop a Cyber Lexicon and to address cyber security and cyber resilience in the financial sector as well as supporting the draft lexicon and the criteria used to develop it. 

A copy of the letter can be viewed here

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Comment Letter, Financial Stability Board

WOCCU Urges FSB to Consider Cooperative Structure on Proposals on Resolution Regimes

The World Council of Credit Unions filed two comment letters with the Financial Stability Board (FSB) on their two Consultation Documents on Key Attributes of Effective Resolution Regimes:  1. Principles on Bail-in Execution; and 2. Funding Strategy Elements of an Implementable Resolution Plan

FSB Bail-In Principles Proposal:

On the FSB Principles on Bail-in Execution WOCCU:

  1. Urges the FSB to limit these requirements to systemically important banks only;
  2. Argues that the FSB should respect the cooperative structure and not require a change in the coop’s ownership and control even in the event of a “bail-in”;
  3. Urges the FSB allow supervisors and institutions the option to engage more than one valuation firm to value its assets;
  4. Argues the FSB should not require community-based depository institutions to invest in computer programs that provide “highly granular” information about their assets and liabilities; and
  5. Cautions that public communications by supervisors concerning troubled financial cooperatives should be carefully crafted so as not to cause a run on that institution or on other financial cooperatives, especially since credit unions and other financial cooperatives are privately held by their member-depositors (so it is not necessary to issue communications to a broader “market” as would likely be necessary for a publicly traded systemically important bank).

FSB Resolution Funding Strategies Proposal: 

WOCCU urged the FSB to apply the proposed funding strategy only to systemically important banks.  Further WOCCU discusses information sharing between institutions and supervisors and provides examples of how cooperative depository institutions systems have handled past resolutions, such as the US “corporate credit unions crisis” of 2009, without demutualizing, such as by using private stabilization funds or temporary public-sector stabilization funds.

A copy of the Bail-In Principles Comment Letter can be viewed here and the Resolution Funding Strategies Proposal Comment Letter can be viewed here.

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Comment Letter, Financial Stability Board

Financial Stability Board Seeks Input on G-SIB Resolution Planning

The Financial Stability Board (FSB) issued for consultation two proposals for guidance on the implementation of its Key Attributes of Effective Resolution Regimes for global systemically important banks (G-SIBs), designed to address the “too-big-to-fail” institutions.

First is the consultation on Principles on Bail-in Execution referring to the write-down and/or conversion of liabilities into equity and helps implement a creditor-financed recapitalization as part of an orderly resolution that minimizes impacts on financial stability, ensures the continuity of critical functions, and avoids exposing taxpayers to loss.

The document proposes a set of principles covering:

  • disclosures on the instruments and liabilities within the scope of bail-in;

  • valuations to inform and support the application of bail-in;

  • processes to suspend or cancel the listing of securities, to notify creditors, and to deliver new securities or tradeable certificates following the entry into resolution;

  • securities law and securities exchange requirements during the bail-in;

  • processes for transferring governance and control rights and establishing a new board for the firm in resolution; and

  • market and creditor communications.

Second, the Consultation on Funding Strategy Elements of an Implementable Resolution Plan proposing guidance on the development of a plan for funding in resolution that builds on the FSB’s August 2016 Guiding Principles on the temporary funding needed to support the orderly resolution of a global systemically important bank (G-SIB) and existing supervisory and resolution guidance on liquidity risk management and resolution planning.

It identifies a set of key funding strategy elements covering:  1.  funding strategy capability; 2. a resolution funding plan by the authorities; 3. the use of firm assets and private sources of funding; 4. access to temporary public sector backstop funding mechanisms; and 5. information sharing and coordination between authorities. 

Comments are due to the FSB by February 2, 2018.

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Financial Stability Board

FSB Issues Report on Financial Sector Cybersecurity Regulations

The Financial Stability Board (FSB) issued its conclusions from a stocktake on cybersecurity regulations, guidance and supervisory practices which was delivered to the October 2017 Finance Minsters and Central Bank Governors in Washington, DC.

Notable findings of the FSB stocktake include the following:

  • All FSB member jurisdictions report drawing upon a small body of previously developed national or international guidance or standards when developing their own regulatory or supervisory schemes for the financial sector;

  • Some elements commonly covered by regulatory schemes targeted to cybersecurity include risk assessment, regulatory reporting, role of the board, third-party interconnections, system access controls, incident recovery, testing and training.

  • Jurisdictions remain active in further developing their regulation and guidance. Seventy-two per cent of jurisdictions report plans to issue new regulations, guidance or supervisory practices that address cybersecurity for the financial sector within the next year.

  • International bodies also have been active in addressing cybersecurity for the financial sector.

Private sector participants in the stocktake expressed support for principles-based, risk-based and proportional regulation, and also stressed the importance of a globally consistent approach that avoids multiple, potentially conflicting regulatory schemes.


The  summary report together with the detailed analysis can be viewed here.

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Financial Stability Board