In two separate comment letters WOCCU urged proportionality and consideration of regulatory restraints for credit unions when implementing requirements for operational resilience and the management of operational risk.
The two related consultations are being proposed by the Basel Committee on Banking Supervision in their Consultative Document: Principles for Operational Resilience and Consultative Document: Revisions to the Principles for the Sound Management of Operational Risk.
In the letter, WOCCU noted that national-level prudential regulators are hesitant to fully proportionally tailor requirements for smaller, community-based financial institutions such as credit unions and therefore requested further emphasis on requiring consideration of proportional implementation of the standard. WOCCU supports many of the principles surrounding operational resilience and the management of operational risk, but believes it should be done in a manner appropriate for credit unions.
A copy of the letters can be viewed here and here.