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TCH Requests Clarification on Basel II Pillar 3 Reporting Deadlines

The Clearing House Association submitted a letter to the OCC, Board of Governors, FDIC and OTS (the “Agencies”) recommending that (i) the Agencies provide sufficient notice to a core bank when granting it permission to exit its parallel run; (ii) the annual Pillar 3 disclosure submission deadlines be no earlier than the corresponding SEC filing deadlines (60 days); (iii) the first Pillar 3 disclosure submission deadline be a minimum of 60 days after quarter end; and (iv) the disclosures described in the Basel Committee's proposed Pillar 3 disclosure requirements for remuneration not be adopted by the Agencies. On December 7 the FRB responded to TCH Association’s letter agreeing with TCH’s recommendations that (i) the annual and first reporting period Pillar 3 disclosures may be published more than 45 days after the end of the calendar quarter, but no later than the applicable SEC guidelines, and (ii) the Fed will notify a banking organization of the successful completion of its parallel run at least 30 days prior to the end of the parallel run period.