Global Correspondence
GFMA Submits Response to BCBS Pillar 3 Climate Disclosure Consult
GFMA submitted a response to the Basel Committee for Banking Supervision (BCBS) Consultative Document on Disclosure of Climate-related Financial risks.
The submission includes response to the consultation questions, as well as a summary of the following overarching comment themes:
- Objective of Pillar 3 disclosures
- The proposed quantitative metrics are not relevant for market assessment of a bank’s capital adequacy and material risk exposure
- Climate-related risk is a driver of traditional risk types, not a standard risk type
- Lack of comparability and consistency of disclosures
- Potential increased liability and legal risk associated with disclosures
- Aim to avoid proliferating climate-related disclosures and different bases for disclosure
- Interoperability with existing data collection and disclosure regimes
- Need for further consultation
– 14 March 2024 –
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