Re: Comments on the BCBS’ Consultative Document on the Definition of Capital Disclosure Requirements

Sep 15, 2026

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Letter submitting comments to the Basel Committee on Banking Supervision regarding its consultative document defining capital disclosure requirements. The Institute of International Finance and The Clearing House Association support transparency and comparability, while cautioning that overly detailed template data in published financial reports may be unhelpful. They recommend focusing reports on summary analyses with links for detailed information, clarify specific template items, and argue for realistic timelines and consistent enforcement across jurisdictions.

LanguageEnglish

CategoryLetters

FormatPDF

Pages4

Reading Time2 min

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Letter Comments on Capital Disclosure Requirements

Support for transparency and comparability

Concerns about report detail and recommended approach

Timeline, enforcement, and peer review assumptions

Comments on specific elements (Annexes)

Andres Portilla Director, Regulatory Affairs Department Institute ofInternational Finance Eli K. Peterson Vice President & Regulatory Counsel The Clearing House Association L.L.C. February 17, 2012 The Honorable Stefan Ingves Chairman Basel Committee on Banking Supervision Centralbahnplatz 2 Basel Switzerland Re: Comments on the BCBS’Consultative Document on the Definition of Capital Disclosure Requirements Dear Chairman Ingves: The Institute of International Finance (IIF) and The Clearing House Association L.L.C. (TCH) would like to thank the Basel Committee for the opportunity to comment on the consultative document on the Definition ofCapital Disclosure Requirements. The IIF and TCH are supportive of the main goal of the consultative document, which is to improve transparency of regulatory capital in order to enhance market discipline. We are also generally supportive of the use of common templates to achieve comparability in disclosures, especially if these templates use terminology consistent across jurisdictions and with other reporting initiatives already in place. The common templates, if implemented appropriately, can lessen the burden on global banks’reporting systems and can assist market participants and supervisors in making more accurate cross-jurisdictional comparisons of banks’capital positions. However, while the data required in the proposed template are generally available to banks, we question whether providing too much detailed information in banks’published financial reports would actually be useful to most market participants. We propose that for such detailed information, banks have the option to make such information available only on their websites (with direct link in the published financial reports), and that the published financial reports be required to focus only on giving summary analyses (directing users to the website for further detailed information) . These summary analyses should include management’s views as well as key information that should be disclosed to the market. We believe therefore that the Basel capital disclosure requirements would benefit from the inclusion of a general guidance as to the types of information that should be highlighted in the published financial reports’summary analyses, rather than focusing solely on the detailed templates. We would also like to express our concern about the proposed date on which the proposed capital disclosure requirements would become effective. It should be noted that banks would still need guidance from national regulators once these proposals are finalized internationally, leaving them with very little time to prepare for the final form of these requirements at the national level. As noted in the Basel Committee’s Progress Report on Basel III implementation (October 2011), a number of jurisdictions have yet to publish draft regulations to implement Basel III. The 2013 implementation date of the new disclosure requirements therefore seems to be unrealistic. In this regard, we would recommend that the Committee provide sufficient lead time for the national implementation of the new requirements. If the goal of comparability and consistency of disclosed information is to be achieved, the Basel Committee should ensure that the disclosure requirements are strictly enforced across jurisdictions. Hence, we are assuming that this will form part of the Basel Committee’s planned peer-review process to assess the implementation of Basel III. In addition to these general comments, we have discussed these proposals with our members and submit the comments on each of the main elements below. • Post 1 January 2018 disclosure template (Annex 1). Providing the detailed information required in this template will not be a problem for banks since this is already required for Basel III monitoring purposes. However, it is questionable whether most market participants would really be interested in the line-by-line items requir

FAQs

What is the main purpose of the letter to the Basel Committee?

The letter provides comments on the Basel Committee’s consultative document defining capital disclosure requirements and addresses how those requirements should be applied for transparency and comparability.

Why do the authors question publishing too much detailed template information in financial reports?

They argue that line-by-line disclosure detail may be uninteresting to most market participants, cluttering reports and making it harder to identify key information; they suggest using summary analyses instead.

What do the authors recommend regarding timelines and enforcement across jurisdictions?

They consider the 2013 effective date unrealistic due to limited national preparation time and recommend sufficient lead time. They also stress strict enforcement across jurisdictions, assuming it aligns with planned peer review to assess Basel III implementation.

Sep 15, 2026

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