BBA has written to the Basel Committee responding to various consultations. Its comment letters cover:
- sound practices for the management and supervision of operational risk: BBA has several concerns about the Basel proposals, including the role envisaged for the board and the suggestion that business process mapping is necessary for all activities;
- supervisory guidelines for Advanced Measurement Approaches (AMA): BBA suggests there may have been insufficient consideration of other risk-sensitive approaches in the wider context of AMA. It welcomes the suggested principles-based approach, but has comments on a number of the key elements proposed by Basel; and
- Pillar 3 disclsosure requirements for remuneration: BBA thinks the proposed guidelines are an important way to standardise supervisory practices but says disclosure must primarily be used to meet investors’ needs.