BRUSSELS, 10 June 2016 – There is a need for proportionality and materiality in the proposed enhancements to Pillar 3 disclosure requirements, according to a detailed reply submitted to the BCBS consultation on the topic. Overall, members made it clear that while they are appreciative of the work done by the BCBS they are of the opinion that the enhancements significantly increase the scope of the information to be disclosed and that the level of granularity of this information is overwhelming. Members are also unsure whether the current draft of the disclosure requirements meets the needs of small and medium banks.
The Basel Committee on Banking Supervision (BCBS) on March 11 of this year issued for consultation proposed enhancements to the Pillar 3 disclosure framework. This consultative document set out proposals from the second phase of the Pillar 3 review. The BCBS issued its revised Pillar 3 disclosure requirements in January 2015, which superseded the Pillar 3 disclosure requirements issued in 2004 (as amended in July 2009), and completed the first phase of the review of Pillar 3 that the Committee announced it was undertaking in its June 2014 Consultative Document.
This consultation details the following elements of the review:
- Enhancements to the revised Pillar 3 framework;
- Further revisions and additions to the Pillar 3 framework arising from ongoing reforms to the regulatory policy framework and;
- Consolidation of all existing and prospective BCBS disclosure requirements into the Pillar 3 framework.
The Basel Committee were keen to receive feedback from both Pillar 3 users and preparers on the proposals and will use this information in finalising the additional tables and templates.
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