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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