Status: Draft -- Not PublishedWill be live at 06/13/2016 00:00
Industry Comments on the Second Phase of Revised Pillar 3 Consultation
The industry comments on the consultation on the second phase of revised Pillar 3 strongly endorse enhancing market understanding of banks' capital and risk profiles; however, there is concern about the quantity, highly technical character, and granularity of information required, which seem likely to contribute to information overload. Moreover, disclosures are proposed on many issues where substantive issues have not been resolved with finality; these disclosures will need to be revised. The proposed hypothetical "benchmark" standardized disclosures for RWAs and market risks risk introducing false comparisons because they would not reflect the true risks. A number of technical issues are also raised that need attention to achieve useful disclosure of Total Loss Absorbing Capacity, market risk, and operational risk.'