Status: Draft -- Not PublishedWill be live at 05/25/2018 00:00
IIF-ISDA-GFMA submit the joint response letter to the Basel Committee's consultation on Pillar 3 disclosure requirements
The IIF, ISDA and GFMA have submitted the joint response letter to the Basel Committee's consultation on Pillar 3 disclosure requirements - updated framework. The Associations, while strongly endorsing underlying policy goals of the Pillar 3, expressed an overall concern about the quantity and granularity of disclosure requirements. To develop more simple, effective and meaningful Pillar 3 disclosures, the industry argued that the current consultation is a proper opportunity to carefully examine and consider the actual current usefulness of granular information in terms of the number of users, the types of users and the actual value added by information usage. The Associations also pointed out that some templates are not appropriate in that they would reveal confidential or proprietary information, undermine the IRB and output floor frameworks, cause unnecessary procyclical market reactions, and cause serious confusion to users.