The IIF is the leading voice for the financial services industry on global regulatory issues. We engage continuously and constructively with global standard setters and policymakers through formal submissions and reports, as well as through regular dialogue and high-level symposia.

We help shape the global policy and regulatory agenda by providing industry input and feedback. We focus on issues such as international capital and liquidity standards for banks and insurers, resolution and recovery policy issues, derivatives market rules, international conduct standards, shadow banking, supervision and risk management, and accounting standards, among many others.

Members participate in working groups and committees with industry peers and interact with public sector representatives, facilitated by the IIF.

February 6, 2015

Please see attached for a brief summary of the key items on the BCBS's Agenda for 2015, and their approximate timing throughout the year. Through our various working groups, we are either currently working on these, or anticipate mobilizing new efforts in the near term.

In part, the attached reflects the high level work plan for the next two years that the BCBS announced in January, collated together with what we have learned from other recent statements and presentations, including some indicative timings within the year. While this summary is very BCBS-specific, it makes passing reference to other FSB and IOSCO initiatives, where these have some interplay.


April 17, 2015

On April 17, the IIF Senior Accounting Group (SAG) submitted its response letter on the IASB’s proposal to amend IAS 7. The proposal aims to address investors’ need to better understand an entity’s period-on-period movements in debt and of any liquidity restrictions that affect an entity’s ability to deploy its resources. While the IIF SAG agrees that these issues are also critical for the banking industry, the current proposal raises a number of concerns that are developed in the attached letter.

April 15, 2015

Ahead of the IMF/World Bank Spring Meetings, IIF President and CEO Tim Adams addressed the challenges for the global economy and financial markets as the impact of regulatory change continues to unfold. In a letter to Chairmen of the International Monetary and Financial committee (IMFC) and the Development Committee (DC), Adams noted three challenges in particular; the deterioration in secondary bond market liquidity in recent years; potential systemic risks associated with a sustained low-rate environment; and facilitating private-sector support for investment, job creation and economic growth more broadly.

April 9, 2015

This month’s IIF Global Regulatory Update provides updates on current work streams in regulatory capital, liquidity, accounting, anti-money laundering, insurance, systemically important financial institutions, derivatives, coherence and calibration as well as upcoming events.

April 6, 2015

The IIF has prepared a brief summary of the key items on the FSB's Agenda for 2015. This reflects the published outcomes from the Brisbane G20 Summit last November and the FSB’s Plenary meeting in Frankfurt on March 26, collated together with what have learned from other recent dialogues and presentations.

Through our various working groups, the IIF is either currently working on these, or anticipate mobilizing new efforts in the near term.

While this summary is FSB-specific, it makes passing reference to other BCBS, IAIS and IOSCO initiatives, where these have some interplay. The IIF also previously prepared a similar summary of the Basel Committee’s agenda for 2015, which can be found at:

March 27, 2015

The IIF, GFMA, the International Swaps and Derivatives Association (ISDA), and The Commercial Real Estate Finance Council (CREFC) provide comment to the Basel Committee on Banking Supervision (BCBS) on their December 2014 Consultative Document, “Capital Floors: the design of a framework based on standardized approaches”

The Associations support the work of the Committee and specifically of the Task Force for Simplicity and Comparability (TFSC) aimed at conducting a comprehensive review of the capital framework and its overall calibration and taking stock of the multiple changes thereto in the course of the past 5 years. The Associations are equally supportive of the Committee’s goal to remove undue complexity and improve the comparability of banks’ capital requirements. The Joint Associations welcome the opportunity to contribute to the discussion on capital floors.

March 27, 2015

The IIF, GFMA and IACPM responded to the proposed revisions to the credit risk standardized approach (SA) issued by the BCBS on December 2014. In their response, the Associations noted that the end-2015 deadline is not realistic given the issues in the proposed conceptual framework as well as the need to conduct a careful impact analysis to ensure appropriate calibration and impact assessment. It was also stressed that credit risk is the cornerstone of the BCBS capital framework and is the most important risk category for most banks, so a more thorough review is warranted. The Associations therefore requested to extend the timeline for this review beyond the planned end-2015 deadline.

Nevertheless, the Associations expressed their readiness and commitment to assisting the TFSA in completing its work. In this regard, the response offered some general remarks as well as detailed comments and alternatives on specific elements of the proposals. The Associations underscored that the extensive nature of the issues that remain to be resolved as well as the need to measure and test quantitatively many different alternatives reinforce the importance of continuing an active dialogue between the BCBS and the industry as the proposals are further developed.

March 26, 2015

On March 25, 2015 the IIF submitted a response letter to the “Notice Seeking Comment on Asset Management Products and Activities” by the Financial Stability Oversight Council (FSOC). The IIF has consistently argued that policy in the area of regulation of systemic risk in asset management should focus primarily on the underlying activities. Thus, the IIF supports the FSOC’s inquiry in general. However, the IIF suggests to expand the scope of the inquiry to include all capital markets participants that might offer a given product or engage in an activity and underscore the need to base any policy in actual, demonstrable data and evidence. The response letter had been produced under the guidance of the IIF’s “Non-Bank Non-Insurer Working Group”.

March 11, 2015

Half of the world’s population is unbanked, but financial inclusion is about more than just having a bank account. Mobile banking and banking via non-bank retail outlets have been key drivers of financial inclusion in developing countries, helped by technology and a favorable regulatory environment. There are clear benefits of financial inclusion at the individual and macro level—even though the macro effects are difficult to quantify. In any case, the benefits of financial inclusion go beyond growth. Financial inclusion is traditionally seen as a developing country issue, but there are broader lessons to learn for the financial industry as it seeks to tap new business opportunities and lower transaction costs.

March 6, 2015

This month’s IIF Global Regulatory Update provides updates on current work streams in regulatory capital, liquidity, recovery and resolution, disclosure, accounting, anti-money laundering, insurance, systemically important financial institutions, derivatives and upcoming events.

March 3, 2015

The IIF has submitted a response letter to the BCBS-IOSCO-IAIS Joint Forum consultation on the Developments in Credit Risk Management Across Sectors: Current Practices and Recommendations.

Significantly, the Joint Forum’s consultative document refers to credit risk models and regulatory capital, which are the subject of two concurrent BCBS consultations, on revisions to the Standardized Approach and the proposed introduction of Capital Floors.