Prudential Regulatory Measures1 in Response to COVID-19 (as of November 22, 2021)

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Prudential Regulatory Measures1 in Response to COVID-19 (as of November 22, 2021)
                                                                                                                    * indicates no recent updates

                                                                                                                               Provisioning, Definition of
                                                                                                                                                                   Consultations/                      Other (reporting, stress
     Jurisdiction                                Capital                                          Liquidity                     Default and NPL-related
                                                                                                                                                              Implementation Timetables                 testing, conduct, etc.)
                                                                                                                                       measures
    FSB                                      2020                                                   2020                   *                                                  2020                                 2020
                             March 20: FSB encouraged local                         March 20: FSB encouraged use of                                          April 2: FSB issued a statement       April 1: The G20 Finance Ministers
                             authorities to support use of                          liquidity buffers to support clients                                     summarizing its coordination          and Central Bank Governors
                             capital buffers by banks to extend                     and ensure functioning of                                                activities, its work on assessing     published a release following their
                             credit. The FSB also announced                         markets.                                                                 financial vulnerabilities and         virtual meeting on March 31
                             coordination efforts among                             July 15: FSB supported the BCBS                                          setting out its re-prioritized 2020   setting out a range of measures
                             authorities.                                           statement on buffer usage and                                            work program and the criteria         including working with the FSB in
                             July 15: FSB supported the BCBS                        announced that supervisors have                                          under which this prioritization is    coordination of regulatory policy
                             statement on buffer usage and                          agreed that banks will be given                                          being determined.                     responses.
                             announced that supervisors have                        sufficient time to restore buffers,                                      September 7: FSB extended the         April 11: FSB issued a letter to
                             agreed that banks will be given                        taking into account economic and                                         implementation dates by one year      G20 finance ministers and central
                             sufficient time to restore buffers,                    market conditions and                                                    for its policy recommendations        bank governors on its vision for
                             taking into account economic and                       individual bank circumstances.                                           related to minimum haircut            post-COVID-19 recovery, including
                             market conditions and                                                                                                           standards for non-centrally           evaluating the effects of reforms
                             individual bank circumstances.                                                                                                  cleared securities financing          and facilitating a smooth
                                                                                                                                                             transactions.                         transition from LIBOR.
                                                                                                                                                                                                   April 15: FSB published a report
                                                                                                                                                                                                   summarizing the principles
                                                                                                                                                                                                   guiding its COVID-19 work, the
                                                                                                                                                                                                   key response measures taken to
                                                                                                                                                                                                   date, financial stability
                                                                                                                                                                                                   implications and future work.

1
 This document captures prudential, securities and related regulatory measures adopted internationally. It does not capture fiscal, monetary and related measures. For access to an IIF compilation of
such measures please follow this link: https://www.iif.com/covid-19 and then navigate to the “COVID-19 Global Policy Response Summary.”

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Provisioning, Definition of
                                                                                                                                             Consultations/            Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables       testing, conduct, etc.)
                                                                                                                  measures
                                                                                                                                                                    April 15: G20 Finance Ministers
                                                                                                                                                                    and Central Bank Governors
                                                                                                                                                                    published a communique in which
                                                                                                                                                                    they committed to use their
                                                                                                                                                                    power to support the economy
                                                                                                                                                                    during COVID-19 and stated their
                                                                                                                                                                    support of the financial measures
                                                                                                                                                                    countries have taken in response
                                                                                                                                                                    to the pandemic.
                                                                                                                                                                    May 26: FSB, in cooperation with
                                                                                                                                                                    BCBS, CPMI, IAIS and IOSCO held a
                                                                                                                                                                    meeting with public and private
                                                                                                                                                                    participants and discussed the
                                                                                                                                                                    effectiveness of prudential and
                                                                                                                                                                    other financial policy measures
                                                                                                                                                                    taken to date, including
                                                                                                                                                                    experiences with their
                                                                                                                                                                    implementation. They also
                                                                                                                                                                    discussed policy issues going
                                                                                                                                                                    forward.
                                                                                                                                                                    July 1: FSB released a statement
                                                                                                                                                                    on the impact of COVID-19 on
                                                                                                                                                                    global benchmark reform.
                                                                                                                                                                    July 15: FSB published a letter
                                                                                                                                                                    from the Chair and a report to
                                                                                                                                                                    G20 Finance Ministers and
                                                                                                                                                                    Governors on the financial
                                                                                                                                                                    stability implications of, and
                                                                                                                                                                    policy measures taken in response
                                                                                                                                                                    to, the COVID-19 pandemic.

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Provisioning, Definition of
                                                                                                                                             Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                                                                                                                                                                    November 17: FSB published a
                                                                                                                                                                    letter from its chair and two
                                                                                                                                                                    reports to G20 Leaders on the
                                                                                                                                                                    holistic review of the March
                                                                                                                                                                    market turmoil and the financial
                                                                                                                                                                    stability impact and policy
                                                                                                                                                                    responses to COVID-19.

                                                                                                                                                                                     2021
                                                                                                                                                                    January 20: FSB published its
                                                                                                                                                                    work program for 2021, reflecting
                                                                                                                                                                    strategic shift in priorities in the
                                                                                                                                                                    COVID-19 environment.
                                                                                                                                                                    February 25: FSB issued a letter to
                                                                                                                                                                    G20 finance ministers and central
                                                                                                                                                                    bank governors including its plans
                                                                                                                                                                    to address COVID-19 related
                                                                                                                                                                    vulnerabilities.
                                                                                                                                                                    April 6: FSB published a letter
                                                                                                                                                                    from the Chair and a report to
                                                                                                                                                                    G20 Finance Ministers and
                                                                                                                                                                    Governors on COVID-19 support
                                                                                                                                                                    measures.
                                                                                                                                                                    July 13: FSB published its Interim
                                                                                                                                                                    Report on the Lessons Learnt
                                                                                                                                                                    from the COVID-19 Pandemic
                                                                                                                                                                    from a Financial Stability
                                                                                                                                                                    Perspective.

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Provisioning, Definition of
                                                                                                                                                                 Consultations/                    Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                  Default and NPL-related
                                                                                                                                                            Implementation Timetables               testing, conduct, etc.)
                                                                                                                                measures
BCBS                                     2020                                                   2020                                  2020                                 2020                                2020
                         March 20: BCBS announced its                           March 20: BCBS supported use of       April 3: BCBS published guidelines   March 20: BCBS said it              April 8: BCBS will not collect Basel
                         support for use of capital buffers                     liquidity buffers and encouraged      on including the risk-reducing       temporarily suspended all open      III monitoring data for the end-
                         by banks to accommodate credit                         the use of HQLA stocks.               effect of measures banks have        consultations and postponed         June 2020 reporting date to
                         and absorb losses during the                           June 17: BCBS discussed the           taken in response to COVID-19        jurisdictional assessments for      increase operational capacity for
                         crisis.                                                impact of COVID-19 and                when calculating regulatory          remainder of 2020.                  banks.
                         June 17: BCBS discussed the                            reiterated guidance on liquidity      capital requirements.                March 27: BCBS announced the        September 25: BCBS approved an
                         impact of COVID-19 and                                 buffers. They also stated that        Additionally, BCBS will amend its    deferral of the Basel III           updated workplan to evaluate its
                         reiterated guidance on capital                         supervisors will provide banks        transitional arrangements for the    implementation deadline by one      post-crisis reforms, which will
                         buffers. They also stated that                         sufficient time to restore buffers,   regulatory capital treatment of      year to January 1, 2023. The        incorporate lessons learned from
                         supervisors will provide banks                         taking into account economic and      ECL accounting.                      deadlines for the revised market    the COVID-19 crisis.
                         sufficient time to restore buffers,                    market conditions and individual                                           risk framework and revised Pillar   November 30: BCBS committed to
                         taking into account economic and                       bank circumstances.                                                        3 disclosure requirements have      continue pursuing a coordinated
                         market conditions and individual                       September 25: BCBS reiterated its                                          also been pushed to January 1,      approach in response to the
                         bank circumstances.                                    previous guidance to make use of                                           2023.                               COVID-19 crisis, including
                         September 25: BCBS reiterated its                      the Basel III capital and liquidity                                        April 3: BCBS will defer the        monitoring risks and encouraging
                         previous guidance to make use of                       buffers.                                                                   implementation of the revised G-    the use of flexibility in the
                         the Basel III capital and liquidity                                                                                               SIB framework by one year, from     regulatory framework.
                         buffers.                                                                2021                                                      2021 to 2022.
                                                                                June 7: BCBS reiterated its                                                April 3: BCBS and IOSCO have                       2021
                                          2021                                  guidance that banks should make                                            agreed to extend the deadline for   April 16: BCBS published its work
                         June 7: BCBS reiterated its                            use of Basel III capital and                                               completing the final two            programme for 2021-22, including
                         guidance that banks should make                        liquidity buffers to absorb shocks                                         implementation phases of the        ongoing Covid-19 initiatives.
                         use of Basel III capital and                           and maintain lending to                                                    margin requirements for non-        July 6: BCBS published a
                         liquidity buffers to absorb shocks                     creditworthy households and                                                centrally cleared derivatives, by   preliminary assessment of the
                         and maintain lending to                                businesses.                                                                one year to September 1, 2022.      impact of implemented Basel
                         creditworthy households and                                                                                                                                           reforms during the pandemic.
                         businesses.

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Provisioning, Definition of
                                                                                                                                                     Consultations/                       Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables                  testing, conduct, etc.)
                                                                                                                    measures
IOSCO                    *                                                      *                                        2020                                  2020                                  2020
                                                                                                          April 3: IOSCO supported             April 3: IOSCO and BCBS have           March 25: IOSCO announced
                                                                                                          professional judgment in applying    agreed to extend the deadline for      coordination activities with other
                                                                                                          accounting standards rather than     completing the final two               standard setters and support for
                                                                                                          applying in a mechanistic manner.    implementation phases of the           actions designed to maintain
                                                                                                                                               margin requirements for non-           market efficiency, liquidity and
                                                                                                                                               centrally cleared derivatives, by      access. Particular focus on
                                                                                                                                               one year to September 1, 2022.         operational and financial
                                                                                                                                               April 8: IOSCO has reprioritized its   resilience of FMIs and information
                                                                                                                                               work program to focus on the           flows.
                                                                                                                                               direct effects of COVID-19 on          May 29: IOSCO issued a
                                                                                                                                               market-based finance.                  statement on the importance of
                                                                                                                                                                                      disclosures concerning COVID-19
                                                                                                                                                                                      related impacts.
IASB                     *                                                      *                                         2020                                 2020                   *
                                                                                                          March 27: IASB released a            March 27: IASB said the release of
                                                                                                          statement clarifying how to apply    several amendments to IFRS
                                                                                                          IFRS 9 during this time of           standards will be delayed until
                                                                                                          uncertainty. The Board also states   May 2020, though IBOR reform
                                                                                                          that it is working with regulators   work and amendments to IFRS 17
                                                                                                          in the current environment and       will proceed as planned.
                                                                                                          encourages companies to              April 10: IASB is considering
                                                                                                          consider guidance provided by        whether to propose a deferral by
                                                                                                          prudential and securities            one year of IFRS Standards,
                                                                                                          regulators.                          extending ongoing consultation
                                                                                                          April 17: IASB decided to propose    periods, and delaying publication
                                                                                                          an amendment to the leases           of new consultations.
                                                                                                          Standard, IFRS 16, to help           April 17: IASB decided to propose
                                                                                                          companies account for covid-19-      extending by one year the
                                                                                                                                               effective date of an amendment

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Provisioning, Definition of
                                                                                                                                                    Consultations/                       Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity        Default and NPL-related
                                                                                                                                               Implementation Timetables                  testing, conduct, etc.)
                                                                                                                      measures
                                                                                                          related rent concessions, such as   to IAS 1, extend three month of
                                                                                                          rent holidays.                      consultation period for three
                                                                                                                                              consultations, and defer several
                                                                                                                                              consultations for a year.
                                                                                                                                              July 15: IASB deferred by one year
                                                                                                                                              the effective date of Classification
                                                                                                                                              of Liabilities as Current or Non-
                                                                                                                                              current within IAS1.
FATF                     *                                                      *                         *                                                  2020                                     2020
                                                                                                                                              April 28: FATF extended deadlines      April 1: FATF released a
                                                                                                                                              for mutual evaluations and             statement on the efforts it has
                                                                                                                                              follow-ups.                            taken in response to COVID-19.
                                                                                                                                                                                     May 4: FATF released a paper on
                                                                                                                                                                                     AML/CFT risks during the COVID-
                                                                                                                                                                                     19 pandemic, along with
                                                                                                                                                                                     recommended policy actions, and
                                                                                                                                                                                     a listing of policy measures
                                                                                                                                                                                     various jurisdictions have taken in
                                                                                                                                                                                     response to the threat.
                                                                                                                                                                                     December 20: FATF published an
                                                                                                                                                                                     update on their report, COVID-19
                                                                                                                                                                                     Related Money Laundering and
                                                                                                                                                                                     Terrorist Financing Risks, that
                                                                                                                                                                                     highlight the latest regulatory
                                                                                                                                                                                     developments.

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Provisioning, Definition of
                                                                                                                                                                 Consultations/                        Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity               Default and NPL-related
                                                                                                                                                            Implementation Timetables                   testing, conduct, etc.)
                                                                                                                             measures
European                                 2020                                                   2020                               2020                                      2020                                  2020
Union                    March 12: ECB said banks can                           March 12: ECB advised it would     March 20: ECB exercised flexibility     March 12: EBA said EU stress-           March 16: ESMA temporarily
                         fully use capital buffers and that                     allow banks to operate             regarding the classification of         tests have been postponed to            lowered the reporting threshold
                         banks will benefit from relief in                      temporarily below the liquidity    debtors as “unlikely to pay” on         2021. In 2020, the EBA will             for holders of net short positions
                         the composition of capital for                         coverage ratio.                    public guarantees granted.              instead carry out an additional         in shares traded on an EU
                         Pillar 2 Requirements. Banks are                       July 28: ECB committed to allow    March 20: ECB recommended               EU-wide transparency exercise.          regulated market.
                         also expected not to increase                          banks to operate below the LCR     that all banks avoid procyclical        March 20: ESMA extended all             March 19: ESMA set out an
                         capital distributions in response                      until at least end-2021, without   assumptions in their models to          consultation deadlines for four         approach to the Securities
                         to these measures.                                     automatically triggering           determine provisions.                   weeks.                                  Finance Transactions Regulation.
                         March 27: ECB asks banks not to                        supervisory actions.               March 25: EBA released a                March 25: EBA said the deadlines        March 20: ESMA clarified its
                         pay dividends for 2019 or 2020                                                            statement on the application of         of ongoing public consultations         position on call taping under
                         until at least October 1, 2020.                                                           the prudential framework with           will be extended by two months          MIFID II.
                         Banks should also refrain from                                                            regards to classification of default,   and public hearings will be             March 27: ESMA recommended
                         share buy-backs aimed at                                                                  forbearance, and IFRS 9.                postponed.                              that Member State authorities
                         remunerating shareholders.                                                                March 25: ESMA issued guidance          March 31: EBA provides details on       accept delayed financial reports
                         March 31: EBA reiterated and                                                              on accounting principles,               its call for leeway on reporting        from issuers.
                         expanded its call to institutions to                                                      including moratoria on repayment        dates, urging one-month flexibility     March 31: ESMA encouraged
                         refrain from the distribution of                                                          of loans and the calculation of         for reports with remittance dates       national competent authorities
                         dividends or share buybacks for                                                           expected credit losses in               between March and the end of            not to prioritize supervisory
                         the purpose of remunerating                                                               accordance with IFRS 9.                 May 2020. EBA also called for           action against execution venues
                         shareholders and assess their                                                             April 2: EBA issued guidelines on       flexibility in assessing deadlines of   and firms in respect of the
                         remuneration policies in line with                                                        the requirements of public and          institutions’ Pillar 3 disclosures.     deadlines of the general best
                         the risks stemming from the                                                               private moratoria given COVID-19.       Also the EBA, in coordination with      execution reports under MiFID II.
                         economic situation.                                                                       April 22: EBA provided further          the BCBS, has decided to cancel         March 31: EBA, in coordination
                         April 1: SRB has published                                                                clarity on the prudential               the Quantitative Impact Study           with the BCBS, has decided to
                         commentary by its Chair which                                                             application of the definition of        (QIS) based on June 2020 data.          cancel the Quantitative Impact
                         acknowledges capital relief                                                               default and forbearance as well as      April 6: European Commission            Study (QIS) based on June 2020
                         measures undertaken by                                                                    how the EBA Guidelines on               extended deadlines for                  data.
                         Authorities in the region and                                                             legislative and non-legislative         responding to its four 2020             April 1: SRB has published
                         states that such measures will be                                                                                                                                         commentary by its Chair which

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Provisioning, Definition of
                                                                                                                                                     Consultations/                      Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables                 testing, conduct, etc.)
                                                                                                                    measures
                         taken into account in future MREL                                                moratoria on loan repayments         banking and finance                   discusses operational relief
                         decisions.                                                                       apply to securitizations.            consultations.                        measures being adopted by the
                         April 8: SRB provided additional                                                 June 19: European Parliament         April 9: ESMA decided to further      Board.
                         clarity on its approach to                                                       approved changes to the capital      extend the response date for the      April 7: ECB announced a series of
                         minimum requirements for own                                                     requirement regulation and           consultation on the MiFID II/MiFIR    collateral easing measures to
                         funds and eligible liabilities                                                   clarified the treatment of IFRS 9    review report to June 14.             increase capacity to provide
                         (MREL), including the setting of                                                 and expected credit loss.            April 9: ESMA postponed the           funding and liquidity.
                         MREL targets, taking the impact                                                  September 21: EBA announced it       application of the annual non-        April 9: ESMA acknowledged that
                         of the COVID-19 crisis into                                                      would phase out certain elements     equity transparency calculations      COVID-19 has made it difficult for
                         account.                                                                         of its legislative and non-          and the calculations for the          fund managers to file certain
                         April 16: ECB announced it will                                                  legislative loan moratoria that      systematic internalizer test for      reports and encouraged National
                         temporarily allow lower capital                                                  were introduced in response to       derivatives, ETCs, ETNs, emission     Competent Authorities to adopt a
                         requirements for market risk by                                                  COVID-19.                                                                  risk-based approach and not
                                                                                                                                               allowances and structured finance
                         reducing the qualitative market                                                  December 2: EBA reactivated its                                            prioritize supervisory actions.
                                                                                                                                               products under MiFID II.
                         risk multiplier for six months.                                                  guidelines on legislative and non-                                         April 9: ESMA issued a statement
                         April 22: EBA proposed to adjust                                                 legislative moratoria until March    May 4: EBA, EIOPA and ESMA
                                                                                                                                                                                     to promote National Competent
                         the capital impact for market risk                                               31, 2021.                            published joint draft Regulatory
                                                                                                                                                                                     Authorities regarding the
                         by amending its standards on                                                     December 16: European                Technical Standards to amend the
                                                                                                                                               Delegated Regulation on the risk      timeliness of fulfilling external
                         prudent valuation, including a use                                               Commission announced an action                                             audit requirements for interest
                         of 66% aggregation factor until                                                  plan to prevent the build-up of      mitigation techniques for non-
                                                                                                                                               centrally cleared OTC derivatives     rate benchmark administrators
                         December 31, 2020.                                                               NPLs due to COVID-19.
                                                                                                                                               to incorporate a one-year deferral    and contributors to interest rate
                         April 28: European Commission
                                                                                                                                               of the two implementation             benchmarks.
                         proposed amendments to the
                         EU's banking prudential rules,                                                                                        phases of the bilateral margining     April 15: ECB issued a non-
                         proposing exceptional temporary                                                                                       requirements.                         objection decision supporting
                         measures by adapting the                                                                                              June 18: EBA extended the             national macroprudential
                         timeline of the application of                                                                                        deadline for the application of its   authorities’ macroprudential
                         international accounting                                                                                              guidelines on payment moratoria       measures taken in response to
                         standards on banks' capital, by                                                                                       by three months to September          COVID-19.
                         treating more favorably public                                                                                        30, 2020. In addition, they
                                                                                                                                               highlighted that the

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Provisioning, Definition of
                                                                                                                                              Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                         Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                         guarantees granted during this                                                                                 implementation timeline      April 15: ESMA said it supports
                         crisis, by postponing the date of                                                                              envisaged in the EBA’s IRB   decisions by national regulators to
                         application of the leverage ratio                                                                              roadmap to repair internal   place restrictions on short selling
                         buffer and by modifying the way                                                                                models remains overall       and is coordinating alignment of
                         of excluding certain exposures                                                                                 unchanged.                   the renewal process.
                         from the calculation of the                                                                                                                 April 22: ECB adopted temporary
                         leverage ratio.
                                                                                                                                                                     measures to mitigate the effect
                         June 19: European Parliament
                                                                                                                                                                     on collateral availability of
                         approved changes to the capital
                         requirement regulation, including                                                                                                           possible rating downgrades.
                         the deferral of implementation of                                                                                                           May 14: ESRB released a
                         the leverage ratio buffer to                                                                                                                statement with a set of
                         January 2023. Although not                                                                                                                  recommended actions in five
                         mentioned in the press release,                                                                                                             priority areas in response to
                         the draft resolution also proposes                                                                                                          COVID-19.
                         additional flexibility to competent                                                                                                         May 14: ESMA expressed its
                         authorities in relation to the                                                                                                              support for ESRB’s proposal that
                         market risk multiplier to mitigate                                                                                                          national regulators enhance
                         the negative effects of the                                                                                                                 supervision of investment funds
                         extreme market volatility.
                                                                                                                                                                     with significant exposures to
                         July 9: EBA released a statement
                                                                                                                                                                     corporate debt and real estate.
                         on resolution planning in
                                                                                                                                                                     May 18: ESMA noted that several
                         light of the COVID-19 pandemic
                         and updated its view on MREL                                                                                                                national regulators did not renew
                         decisions.                                                                                                                                  emergency restrictions on short
                         July 28: ECB extended its                                                                                                                   selling and similar transactions.
                         recommendation that banks not                                                                                                               June 2: EBA released guidelines to
                         pay dividends until January 2021                                                                                                            address gaps in reporting and
                         and issued a letter with its                                                                                                                disclosure caused by COVID-19.
                         expectation that banks exercise

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Provisioning, Definition of
                                                                                                                                             Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                         extreme moderation on variable                                                                                                             June 8: ESRB released a statement
                         remuneration to conserve capital.                                                                                                          detailing its second set of actions
                         July 28: ECB committed to allow                                                                                                            in response to COVID-19,
                         banks to operate below the P2G                                                                                                             including a recommendation that
                         and the combined buffer                                                                                                                    distributions be restricted.
                         requirement until at least end-                                                                                                            June 11: ESMA renewed its
                         2022, without automatically                                                                                                                decision to temporarily require
                         triggering supervisory actions.                                                                                                            the holders of net short positions
                         September 17: ECB announced                                                                                                                to notify the relevant national
                         that it would allow banks to                                                                                                               competent authority if the
                         exclude central bank exposures                                                                                                             position exceeds 0.1% of the
                         from the leverage ratio until June                                                                                                         issued share capital.
                         27, 2021.
                                                                                                                                                                    July 7: EBA released a report
                         December 15: ECB asked banks to
                                                                                                                                                                    clarifying the implementation of
                         refrain from or limit (according to
                         certain rules) dividends and share                                                                                                         adjustments to the prudential
                         buybacks until September 2021.                                                                                                             framework due to COVID-19.
                         December 15: EBA asked banks to                                                                                                            August 7: EBA provided clarity on
                         follow conservative capital                                                                                                                the implementation of the
                         distribution strategies.                                                                                                                   reporting and disclosure
                         December 18: ESRB issued revised                                                                                                           framework in the context of
                         expectations on the restriction of                                                                                                         COVID-19 measures.
                         dividends.                                                                                                                                 August 11: EBA published
                                                                                                                                                                    guidance on the impact of CRR
                                        2021                                                                                                                        adjustments in response to the
                         January 29: EBA published
                                                                                                                                                                    COVID‐19 pandemic on
                         guidelines on the prudential
                                                                                                                                                                    supervisory reporting and
                         framework in response to COVID-
                         19-related questions.                                                                                                                      disclosure.

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Provisioning, Definition of
                                                                                                                                             Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                         June 18: ECB extended leverage                                                                                                             August 14: EBA updated its work
                         ratio relief for banks to exclude                                                                                                          program for 2020 in light of the
                         certain central bank exposures                                                                                                             COVID-19 pandemic.
                         until March 2022.                                                                                                                          September 17: ESMA renewed its
                         July 23: ECB decided not to                                                                                                                decision to temporarily require
                         extend dividend recommendation                                                                                                             the holders of net short positions
                         beyond September 2021.
                                                                                                                                                                    to notify the relevant national
                                                                                                                                                                    competent authority if their
                                                                                                                                                                    position exceeds 0.1% of the
                                                                                                                                                                    issued share capital.
                                                                                                                                                                    September 30: EBA published its
                                                                                                                                                                    work program for 2021, including
                                                                                                                                                                    work to address the effects of
                                                                                                                                                                    COVID.
                                                                                                                                                                    December 17: ESMA renewed its
                                                                                                                                                                    decision requiring holders of net
                                                                                                                                                                    short positions to notify
                                                                                                                                                                    regulators if the position reaches,
                                                                                                                                                                    exceeds or falls below 0.1% of the
                                                                                                                                                                    issued share capital.

                                                                                                                                                                                    2021
                                                                                                                                                                    January 28: ECB published the
                                                                                                                                                                    outcome of its 2020 Supervisory
                                                                                                                                                                    Review and Evaluation Process
                                                                                                                                                                    and announced its supervisory
                                                                                                                                                                    priorities for 2021.

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Provisioning, Definition of
                                                                                                                                             Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                                                                                                                                                                    January 29: ECB announced it will
                                                                                                                                                                    conduct a stress test which will
                                                                                                                                                                    replace the 2020 EBA stress test
                                                                                                                                                                    postponed due to COVID-19.
                                                                                                                                                                    March 15: ESMA decided not to
                                                                                                                                                                    renew its decision to require
                                                                                                                                                                    holders of net short positions to
                                                                                                                                                                    notify the relevant national
                                                                                                                                                                    competent authority if the
                                                                                                                                                                    position reaches, exceeds or falls
                                                                                                                                                                    below 0.1% of the issued share
                                                                                                                                                                    capital.
                                                                                                                                                                    May 20: ESMA recommended to
                                                                                                                                                                    the European Commission to
                                                                                                                                                                    permanently lower the threshold
                                                                                                                                                                    to notify net short positions on
                                                                                                                                                                    shares to national competent
                                                                                                                                                                    authorities from 0.2% to 0.1%.
                                                                                                                                                                    May 27: EBA published a thematic
                                                                                                                                                                    note looking into macroeconomic
                                                                                                                                                                    impact of the pandemic, in banks’
                                                                                                                                                                    loan portfolios, and in accounting
                                                                                                                                                                    rules between the U.S. and the
                                                                                                                                                                    E.U.
                                                                                                                                                                    June 3: EBA published its 2020
                                                                                                                                                                    Annual Report, which presents
                                                                                                                                                                    the ad-hoc activities the EBA
                                                                                                                                                                    undertook to mitigate the impact

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                     Page 12
Provisioning, Definition of
                                                                                                                                                                  Consultations/                     Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                  Default and NPL-related
                                                                                                                                                             Implementation Timetables                testing, conduct, etc.)
                                                                                                                                measures
                                                                                                                                                                                                 of COVID-10 on the EU banking
                                                                                                                                                                                                 sector.
                                                                                                                                                                                                 September 8: EBA, EIOPA and
                                                                                                                                                                                                 ESMA published a joint assemnet
                                                                                                                                                                                                 report highlighting risks in phasing
                                                                                                                                                                                                 out of crisis measures.
United States                             2020                                                   2020                                  2020                                 2020                                 2020
                         March 17: FRB, FDIC, and OCC                           March 17: FRB, FDIC, and OCC          March 19: The FDIC Chairman           March 24: FRB stated that it will    March 24: FRB announces
                         encouraged banks to use their                          encouraged banks to use their         asked FASB to delay transitions to    grant firms additional time to       adjustments to its supervisory
                         capital buffers and issued an                          liquidity buffers.                    certain accounting rules including    resolve non-critical existing        approach with increased
                         interim final rule to introduce a                      April 23: FRB announced               those related to CECL and TDR         supervisory findings, but CCAR       monitoring and outreach and
                         technical change to make any                           temporary measures to help            classifications.                      capital plans should still be        reduced examination activities,
                                                                                                                      March 22: FRB, CSBS, CFPB, FDIC,      submitted by April 6.                especially for small financial
                         automatic limitations on capital                       increase the availability of
                                                                                                                      NCUA, and OCC announced they          March 31: FRB said it would delay    institutions.
                         distributions more gradual.                            intraday credit by suspending
                                                                                                                      will not direct institutions to       the effective date for its revised   March 24: FRB delayed the
                         March 23: FRB issued an interim                        uncollateralized intraday credit      automatically categorize loan         control framework by six months.     implementation of changes to
                         final rule to introduce a technical                    limits and permitting a               modifications as troubled debt        April 2: FRB, FDIC, OCC, SEC, and    procedures governing the
                         change to make any automatic                           streamlined procedure for             restructurings.                       CFTC said they would consider        provision of intraday credit to U.S.
                         limitations on capital distributions                   secondary credit institutions to      March 27: FRB, FDIC, and OCC          comments on their proposal to        branches and agencies of foreign
                         under the TLAC rule more                               request collateralized intraday       announced an interim final rule       update the Volcker Rule’s covered    banking organizations by six
                         gradual.                                               credit.                               that would provide flexibility to     funds provision until May 1, a       months.
                         March 27: FRB, FDIC, and OCC                                                                 allow banks to mitigate the           month later than originally          March 25: SEC has extended
                                                                                May 5: FRB, FDIC, and OCC
                         said they would allow early                                                                  effects of CECL.                      announced.                           certain reporting deadlines for
                                                                                announced an interim final rule to
                         adoption of SA-CCR.                                                                          April 7: SEC said that financial      April 10: CFTC announced it          public companies and issued
                         April 1: FRB announced a                               adjust the Liquidity Coverage
                                                                                Ratio for banks participating in      institutions that take advantage of   would extend deadlines for           guidance on COVID-19 related
                         temporary change to its                                                                      the CARES Act provision that          certain open consultations.          disclosures.
                         supplementary leverage ratio                           the Money Market Mutual Fund
                                                                                                                      allows the deferral of                April 27: FRB and FDIC announced     March 31: CFTC has issued no-
                         rule, which would exclude U.S.                         Liquidity Facility and the Paycheck
                                                                                                                      implementation of two GAAP            that they would extend the           action relief to foreign affiliates of
                         Treasury securities and deposits                       Protection Program Liquidity
                                                                                                                                                            comment period for their             certain futures commission
                                                                                Facility.

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                                      Page 13
Provisioning, Definition of
                                                                                                                                                     Consultations/                     Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables                testing, conduct, etc.)
                                                                                                                    measures
                         at Federal Reserve Banks from the                                                standards will not be in violation   proposed guidance for large          merchants affected by COVID-19,
                         calculation of the rule for holding                                              of GAAP.                             foreign banks’ resolution plans by   which will last until September 30.
                         companies until March 31, 2021.                                                  April 22: OCC, FRB, and FDIC         30 days.                             April 8: SEC issued a statement on
                         April 6: FRB, FDIC, and OCC                                                      announced a final rule with          May 6: FRB and FDIC extended         the importance of robust
                         announced two interim final rules                                                changes to the interim final rule    the deadlines for two resolution     disclosures and reporting during
                         for community banks, including a                                                 of March 27 on CECL                  plan requirements.                   COVID-19.
                         change to the community bank                                                     implementation.                                                           April 14: FRB, FDIC, OCC, NUCA,
                                                                                                                                               May 28: CFTC approved an
                         leverage ratio.                                                                                                                                            and CFPB issued an interim final
                                                                                                                                               interim final rule to grant an
                         April 7: FRB, OCC, FDIC, CFPB and                                                                                                                          rule to temporarily defer real
                                                                                                                                               extension of the compliance          estate-related appraisals and
                         NCUA issued a revised
                                                                                                                                               schedule for initial margin          evaluations and related reporting
                         interagency statement on loan
                                                                                                                                               requirements for uncleared swaps     requirements under the agencies'
                         modifications. The statement
                         includes supervisory                                                                                                  in response to COVID-19.             interagency appraisal regulations.
                         interpretations on past due and                                                                                       June 10: CFTC extended elements      June 15: FRB announced that it
                         nonaccrual regulatory reporting                                                                                       of its COVID-19 no-action relief     will resume examination activities
                         of loan modification programs                                                                                         through September 30, 2020.          for all banks, after previously
                         and regulatory capital.                                                                                                                                    announcing a reduced focus on
                         April 9: FRB, FDIC, and OCC                                                                                                                                exam activity in light of COVID-19.
                         announced an interim final rule to                                                                                                                         June 23: FRB, FDIC, OCC, NCUA,
                         encourage lending through the                                                                                                                              and state regulators issued
                         Small Business Administration's                                                                                                                            guidance to examiners to
                         Paycheck Protection Program                                                                                                                                promote consistency and
                         (PPP), clarifying that a zero                                                                                                                              flexibility in oversight of financial
                         percent risk weight applies to                                                                                                                             institutions affected by COVID-19.
                         loans covered by the PPP for
                         capital purposes.
                         April 30: FRB clarified that the
                         interest in a Main Street
                         loan retained by an Eligible
                         Lender should be

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                        Page 14
Provisioning, Definition of
                                                                                                                                             Consultations/         Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables    testing, conduct, etc.)
                                                                                                                  measures
                         assigned the risk weight
                         applicable to the counterparty for
                         the loan in a FAQ.
                         May 15: FRB, FDIC, and OCC
                         announced an interim final rule
                         permitting depository institutions
                         to choose to exclude U.S.
                         Treasury securities and deposits
                         at Federal Reserve Banks from the
                         calculation of the supplementary
                         leverage ratio.
                         June 25: FRB decided to suspend
                         share repurchases and restrict
                         dividends for the third quarter of
                         2020.
                         September 29: FRB finalized a
                         rule to neutralize the regulatory
                         capital and liquidity effects for
                         banks that participate in certain
                         Fed liquidity facilities.
                         September 30: FRB extended for
                         an additional quarter measures
                         prohibiting share repurchases and
                         the capping of dividend
                         payments.
                         December 18: FRB, after
                         conducting a second round of
                         bank stress tests, will limit
                         dividends and share repurchases

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                               Page 15
Provisioning, Definition of
                                                                                                                                                                    Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                  Default and NPL-related
                                                                                                                                                               Implementation Timetables        testing, conduct, etc.)
                                                                                                                                measures
                         based on income for the past year
                         in Q1 of 2021.
                         December 18: FRB will keep the
                         CCyB at 0%.

                                          2021
                         March 19: FRB, FDIC, and OCC
                         announced that the temporary
                         change to the supplementary
                         leverage ratio issued on May 15,
                         2020, will expire as scheduled on
                         March 31, 2021.
                         March 25: FRB said that dividend
                         and share repurchase restrictions
                         will be lifted after June 30 for
                         banks that are well-capitalized
                         according to recent stress tests.
Argentina                *                                                      *                                                    2020                  *                               *
                                                                                                                      March 19: Central Bank of the
                                                                                                                      Argentine Republic arranged for
                                                                                                                      the provisional flexibility of the
                                                                                                                      parameters with which bank
                                                                                                                      debtors are classified.
Australia                               2020                                                     2020                                   2020                               2020                           2020
                         March 19: APRA announced                               March 30: APRA allows                 March 23: APRA provided              March 23: APRA said it is       April 1: APRA announced changes
                         support for use of capital buffers                     authorized deposit-taking             flexibility for treatment of         suspending all prudential       to reporting obligations in
                         to promote ongoing lending to                          institutions to include the benefit   payment holidays and                 framework consultations and     response to COVID-19.
                         the economy.                                           of the Initial Allowance in the       reorganized loan repayments that     actions on all non-essential

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                          Page 16
Provisioning, Definition of
                                                                                                                                                               Consultations/                       Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity               Default and NPL-related
                                                                                                                                                          Implementation Timetables                  testing, conduct, etc.)
                                                                                                                             measures
                         April 7: APRA released a                               calculation of the Liquidity       such arrangements are not             matters until at least September       April 1: APRA and ASIC release a
                         statement that it expects ADIs                         Coverage Ratio, Minimum            treated as in arrears or              30, 2020. The implementation           letter on the impact of COVID-19
                         and insurers to limit discretionary                    Liquidity Holdings Ratio and Net   restructured.                         dates for recently finalized rules     for superannuation trustees.
                         capital distributions, including                       Stable Funding Ratio from 31       July 8: APRA announced an             will be reconsidered.                  April 8: APRA will suspend issuing
                         dividends. The statement includes                      March 2020.                        extension of its temporary capital    March 23: ASIC has immediately         new banking or insurance licenses
                         guidance for determining                                                                  treatment for bank loans with         suspended a number of near-term        for at least six months.
                         distributions. APRA also expects                                                          repayment deferrals, as well as       activities which are not time-         April 8: ASIC released feedback on
                         that Boards will appropriately                                                            temporarily adjusting the capital     critical, including consultation and   financial institutions' preparation
                         limit executive cash bonuses.                                                             treatment of restructured loans.      reviews.                               for LIBOR transition recognizing
                         May 7: APRA released an FAQ on                                                            September 9: APRA issued a letter     March 30: APRA announced it is         that disruptions from the COVID-
                         its expectations for the regulatory                                                       outlining its response to its         deferring its scheduled                19 outbreak may affect the timing
                         capital approach for loan                                                                 consultation on capital measures      implementation of the Basel III        of some aspects of institutions’
                         repayment deferrals and                                                                   and reporting requirements for        reforms in Australia by one year.      transition plans.
                         clarifications on its guidance for                                                        loans impacted by COVID-19.           April 16: APRA announced new           April 14: ASIC released a
                         mortgage lending.                                                                                                               commencement dates for                 statement detailing how its
                         May 19: APRA published an FAQ                                                                            2021                   prudential and reporting               regulatory work and priorities
                         on market risk capital                                                                    July 19: APRA announced               standards.                             have changed in response to
                         requirements in response to                                                               regulatory support for banks          August 10: APRA announced it           COVID-19.
                         COVID-19.                                                                                 offering temporary financial          will recommence public                 August 31: APRA has published its
                         June 17: APRA updated its FAQ to                                                          assistance to borrowers impacted      consultations on select policy         2020-2024 Corporate Plan, which
                         provide clarification on the                                                              by COVID-19, largely mirroring the    reforms and begin a phased             has been updated to account for
                         standardized approach to credit                                                           temporary support measures            resumption of the issuing of new       the substantial impact of the
                         risk-weighted assets.                                                                     APRA announced in March 2020.         licenses.                              COVID-19 pandemic.
                         July 29: APRA updated its capital                                                         August 25: APRA is extending the
                         management guidance for banks                                                             time period for the temporary                                                              2021
                         and insurers, easing restrictions                                                         adjustments to APS 220 to apply                                              February 1: APRA announced its
                         around paying dividends.                                                                  to loans granted repayment                                                   2021 supervision and policy
                         August 13: APRA issued a                                                                  deferrals from 8 July 2021 until 30                                          priorities.
                         consultation letter to banks                                                              September 2021.
                         regarding capital measures and

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                                  Page 17
Provisioning, Definition of
                                                                                                                                                        Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                   Implementation Timetables        testing, conduct, etc.)
                                                                                                                    measures
                         reporting requirements for loans
                         affected by COVID-19.
                         December 15: APRA said it will no
                         longer hold banks to a minimum
                         level of earnings retention but
                         expects them to be cautious when
                         calculating dividends.
                         December 21: APRA announced it
                         would keep the CCyB at 0%.
Belgium                                   2020                                  *                                         2020                 *                                              2020
                         March 11: National Bank of                                                       April 15: National Bank of Belgium                                   March 13: National Bank of
                         Belgium lowered the counter-                                                     released a Q&A for credit                                            Belgium wrote to its banks
                         cyclical buffer level from 0.5% to                                               institutions on the moratorium                                       welcoming the measures of
                         0% to support banks in extending                                                 and guarantee scheme including                                       EBA/ECB and stating its intention
                         credit facilities to customers.                                                  prudential and accounting                                            to apply them in full.
                         April 1: National Bank of Belgium                                                implications.                                                        March 17: FSMA announces
                         expects banks to comply with ECB                                                                                                                      prohibition of short selling.
                         recommendation regarding                                                                                                                              April 2: FSMA announced an
                         dividend distribution policy in the                                                                                                                   explanation regarding recording
                         context of the management of the                                                                                                                      of telephone conversation under
                         coronavirus.                                                                                                                                          MiFID II.
                         June 30: National Bank of Belgium                                                                                                                     April 14: National Bank of Belgium
                         said it would keep the                                                                                                                                announced an extension for
                         countercyclical capital buffer at                                                                                                                     certain reporting requirements in
                         0% in Q3.                                                                                                                                             accordance with EU-level
                         July 30: National Bank of Belgium                                                                                                                     changes.
                         extended its recommendation to                                                                                                                        April 15: FSMA extended the
                         suspend dividend payments until                                                                                                                       prohibition of short selling until
                         at least January 1, 2021 and                                                                                                                          May 18.
                         encouraged a cautious attitude

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                Page 18
Provisioning, Definition of
                                                                                                                                             Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                         towards variable remuneration                                                                                                              May 18: FSMA suspended the ban
                         and profit sharing.                                                                                                                        on creating or increasing net short
                         September 30: National Bank of                                                                                                             positions as of May 19.
                         Belgium kept the countercyclical
                         capital buffer at 0% and
                         maintained its expectation not to
                         increase at least until Q3 2021.
                         December 18: National Bank of
                         Belgium asked institutions to
                         refrain from or limit paying
                         dividends through September 30,
                         2021.
                         December 23: National Bank of
                         Belgium said it would keep the
                         CCyB at 0% for Q1 2021.

                                        2021
                         March 31: National Bank of
                         Belgium said it would keep the
                         CCyB at 0% for Q2 2021.
                         June 23: National Bank of Belgium
                         said it would keep the CCyB at 0%
                         for Q3 2021.
                         September 28: National Bank of
                         Belgium decided to lapse decision
                         on dividend restrictions at the end
                         of September but reminded that
                         banks need to remain prudent
                         when deciding on dividends,

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                      Page 19
Provisioning, Definition of
                                                                                                                                                                  Consultations/                     Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                 Default and NPL-related
                                                                                                                                                             Implementation Timetables                testing, conduct, etc.)
                                                                                                                               measures
                         share buy-backs and variable
                         remuneration.
                         September 30: National Bank of
                         Belgium decided to keep the CCyB
                         at 0% for Q4 2021.

Brazil                                  2020                                                   2020                                 2020                                   2020                  *
                         March 16: Banco Central do Brasil                      Late February: Banco Central do      March 16: Banco Central do Brasil      April 20: Banco Central do Brasil
                         reduced the Conservation Capital                       Brasil reduced the reserve           reduced provisioning rules for the     postponed the deadline of Pillar 3
                         Buffer from 2.5% to 1.25% for one                      requirement ratio on time            refinancing of certain loans for six   reporting to June 30.
                         year.                                                  deposits and increased the           months.
                                                                                amount of reserves considered
                                                                                High Quality Liquid Assets.
Canada                                  2020                                                     2020                                 2020                                 2020                                  2020
                         March 13: OSFI lowered the                             March 27: OSFI announced             March 27: OSFI announced               March 13: OSFI said that no buffer   April 3: OSFI released a statement
                         Domestic Stability Buffer                              flexibility adjustments to the LCR   transitional arrangements for          increases would happen for at        detailing the steps it has taken to
                         requirement from 2.25% of RWA                          and NSFR frameworks and              expected loss provisioning and         least 18 months.                     support the resilience of financial
                         to 1% of RWA.                                          encouraged banks to utilize          provided guidance to the               March 13: OSFI said that it will     institutions.
                         March 13: OSFI set out an                              liquidity pools.                     application of IFRS9. They also        suspend all consultations and new    April 9: OSFI announced
                         expectation that dividend                                                                   stated that loans subject to           policy development.                  extensions of several regulatory
                         increases and share buybacks                                                                payment deferral arrangements          March 27: OSFI acknowledged          filings.
                         should be paused.                                                                           will not be deemed as non-             and adopted the revised BCBS         April 16: OSFI released a
                         March 27: OSFI encouraged banks                                                             performing.                            timetable for Basel III              comprehensive FAQ to explain the
                         to use leverage ratio buffers and                                                           April 9: OSFI expressed their view     implementation. Further they         policy responses it has taken in
                         announced transitional                                                                      that a maximum add-back of 70%         announced that the                   regard to COVID-19.
                         arrangements for capital                                                                    of allowances to Common Equity         implementation date for FRTB         June 8: OSFI further extended
                         treatment of expected loss                                                                  Tier 1 capital is appropriate for      and CVA will be delayed until        2020 regulatory return
                         provisioning.                                                                               ECL accounting.                        January 2024.                        implementation deadlines.

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                                  Page 20
Provisioning, Definition of
                                                                                                                                                     Consultations/                    Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables               testing, conduct, etc.)
                                                                                                                    measures
                         March 30: OSFI determines                                                        August 31: OSFI will gradually       April 9: OSFI extended the          August 6: OSFI published a
                         capital treatment of loans to                                                    phase out the special capital        deadline for the implementation     newsletter including plans to
                         SMEs under programs to support                                                   treatment of loan deferrals that     of the final two phases of the      restart policy development and
                         COVID-19 efforts.                                                                was provided to banks at the start   initial margin requirements for     consultations with the financial
                         April 9: OSFI temporarily excluded                                               of the pandemic.                     non-centrally cleared derivatives   sector.
                         central bank reserves and HQLA                                                                                        by one year.
                         sovereign-issued securities from
                         the leverage ratio exposure
                         measure.
                         April 9: OSFI is lowering the
                         capital floor factor from 75% to
                         70% until the domestic
                         implementation of the Basel III
                         capital floor expected in Q1 2023.
                         April 17: OSFI has released a
                         COVID-19-related explanatory
                         memo on Basel III and bank
                         capital, buffer utilization, and
                         related dividend restrictions.
                         May 1: OSFI issued a letter stating
                         expectations on the use of Pillar II
                         capital buffers for DTIs using the
                         Standardized Approach to credit
                         risk.
                         June 23: OSFI announced that the
                         Domestic Stability Buffer will
                         remain at 1% of total risk-
                         weighted assets.

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                     Page 21
Provisioning, Definition of
                                                                                                                                             Consultations/         Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables    testing, conduct, etc.)
                                                                                                                  measures
                         July 15: OSFI released a statement
                         supporting the recent statements
                         issued by the BCBS and the FSB
                         reinforcing the usability of banks'
                         capital buffers.
                         November 5: OSFI extended the
                         exclusion of central bank reserves
                         and sovereign-issued securities
                         from leverage ratio exposure
                         measures until December 31,
                         2021.
                         December 8: OSFI announced
                         that the Domestic Stability Buffer
                         would remain at 1%.
                         December 14: OSFI reconfirmed
                         its position that banks should be
                         conservative with capital
                         distributions and released certain
                         guidelines.

                                        2021
                         January 27: OSFI announced its
                         policy on the capital treatment of
                         loans through a new federal
                         program to support highly
                         affected business sectors.
                         March 16: OSFI announced the
                         unwinding of regulatory

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                               Page 22
Provisioning, Definition of
                                                                                                                                                                 Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                    Default and NPL-related
                                                                                                                                                            Implementation Timetables        testing, conduct, etc.)
                                                                                                                                  measures
                         adjustments to the market risk
                         capital requirements for banks,
                         effective May 1, 2021.
                         June 17: OSFI decided to increase
                         the Domestic Stability Buffer to
                         2.5% from October 31, 2021.
                         August 12: OSFI confirmed that
                         the exclusion of sovereign-issued
                         securities from the leverage ratio
                         exposure measure will not be
                         extended past December 31,
                         2021.
                         November 4: OSFI announced to
                         lift expectations on dividends,
                         share repurchases and executive
                         compensation.
China                                    2020                                                   2020                  *                                 *                               *
                         October 1: PBOC and CBIRC                              April 3: PBOC will cut the required
                         established the Countercyclical                        reserve ratio for small and
                         Capital Buffer and clarified that                      medium banks by 1% with
                         the ratio will be initially set at                     reductions of 0.5% on both April
                         zero.                                                  15 and May 15.
                                                                                April 7: PBOC released an FAQ on
                                                                                targeted reserve ratio
                                                                                requirement cuts.

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                       Page 23
Provisioning, Definition of
                                                                                                                                                                Consultations/                     Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                 Default and NPL-related
                                                                                                                                                           Implementation Timetables                testing, conduct, etc.)
                                                                                                                               measures
Finland                                   2020                                                   2020                                2020                                2020                                  2020
                         March 16: FIN-FSA confirmed that                       March 16: FIN-FSA confirmed that     April 6: FIN-FSA announced that it   March 24: FIN-FSA extended time      June 25: FIN-FSA confirmed that
                         banks are temporarily exempt                           banks are temporarily exempt         will comply with EBA standards on    for reporting by non-life and life   only parts of the EBA Guidelines
                         from fulfilling certain additional                     from fulfilling certain additional   legislative and non-legislative      insurance companies.                 published June 2 on additional
                         capital requirements.                                  liquidity requirements.              moratoria on loan repayments.        June 29: FIN-FSA will comply with    reporting and disclosure
                         March 17: FIN-FSA lowered bank                                                              May 7: FIN-FSA clarified that        the EBA’s extension of payment       requirements in the context of
                         capital requirements by 1% by                                                                                                    moratoria deadlines to September     COVID-19 will be mandatory.
                                                                                                                     adoption of a transitional
                         removing the systemic risk buffer                                                                                                30.                                  July 3: FIN-FSA said that in line
                                                                                                                     provision under the CRR may be
                         and adjusting bank-specific                                                                                                                                           with an earlier ESMA decision, the
                         requirements of all credit                                                                  used to mitigate the impact of                                            net short position reporting
                         institutions.                                                                               expected credit-loss provisioning                                         threshold remains at 0.1%.
                         March 17: FIN-FSA will closely                                                              under IFRS 9 on CET1.
                         monitor that banks use the                                                                  August 20: FIN-FSA announced it
                         positive effects of measures to                                                             has applied the updated EBA
                         mitigate the impact of the crisis                                                           guidelines on legislative and non-
                         and not to channel them into the                                                            legislative moratoria on loan
                         payment of dividends or                                                                     repayments.
                         performance bonuses.
                         March 30: FIN-FSA issued a                                                                                  2021
                         recommendation to supervised
                                                                                                                     January 28: FIN-FSA has applied
                         banks to refrain from dividend
                                                                                                                     the updated EBA guidelines on
                         distributions until October 1.
                                                                                                                     legislative and non-legislative
                         April 6: FIN-FSA decided to
                                                                                                                     moratoria on loan repayments.
                         remove the additional capital
                         requirement of the systemic risk
                         buffer for certain banks in
                         addition to other systemically
                         important institutions.
                         June 29: FIN-FSA decided to
                         maintain the countercyclical

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                                Page 24
Provisioning, Definition of
                                                                                                                                             Consultations/         Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables    testing, conduct, etc.)
                                                                                                                  measures
                         capital buffer rate at 0.0% and
                         relaxed the residential mortgage
                         loan cap.
                         July 29: FIN-FSA extended the
                         validity of its profit distribution
                         recommendation that credit
                         institutions under its supervision
                         do not pay or commit to pay
                         dividends or other profit
                         distributions until January 1,
                         2021. The recommendation also
                         applies to repurchases and
                         redemptions of shares.
                         September 30: FIN-FSA decided to
                         maintain the countercyclical
                         capital buffer rate at 0% and kept
                         the loan caps unchanged.
                         December 18: FIN-FSA requested
                         extreme prudence in profit
                         distributions until September 30,
                         2021.
                         December 18: FIN-FSA said it
                         would keep the loan cap and CCyB
                         unchanged.

                                       2021
                         February 17: FIN-FSA announced
                         amendments to its regulations

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                               Page 25
Provisioning, Definition of
                                                                                                                                                        Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                   Implementation Timetables        testing, conduct, etc.)
                                                                                                                    measures
                         and guidelines related to EU
                         Capital Requirements Regulation.
                         March 18: FIN-FSA announced
                         that the maximum loan-to-
                         collateral (LTC) ratio and banks’
                         capital requirements will remain
                         unchanged.
                         June 29: FIN-FSA lowered the
                         loan cap for residential mortgage
                         loans by five percentage points
                         and maintained the CCyB rate at
                         0%.
                         July 27: FIN-FSA decided not to
                         extend its recommendation on
                         distribution of credit institutions’
                         profits beyond 30 September
                         2021.
                         September 24: FIN-FSA decided
                         to maintain the CCyB rate at 0.0%.
France                                  2020                                    *                                        2020                  *                                               2020
                         March 18: French authorities to                                                  April 7: AMF clarified accounting                                    March 17: AMF announced a
                         reduce the countercyclical capital                                               standards for calculation of                                         short selling ban for one month.
                         buffer from 0.25% RWA to 0%                                                      expected credit losses in light of                                   April 8: AMF has published a
                         RWA in accordance with the ECB                                                   recent announcements from                                            statement clarifying appropriate
                         proposal.                                                                        ESMA, EBA, and IASB.                                                 fund and risk management
                         March 30: ACPR called on credit
                                                                                                                                                                               protocols for asset managers
                         institutions under its direct
                                                                                                                                                                               during the COVID-19 crisis.
                         supervision and finance

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                Page 26
Provisioning, Definition of
                                                                                                                                             Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                         companies to refrain from                                                                                                                  April 9: ACPR announces a
                         distributing dividends or                                                                                                                  relaxation of the reporting
                         undertaking buybacks until at                                                                                                              conditions for the banking sector.
                         least October 1.                                                                                                                           April 15: AMF announced the
                         April 1: High Council for Financial                                                                                                        extension of the net short
                         Stability lowered the                                                                                                                      position ban until May 18, 2020
                         countercyclical capital buffer to                                                                                                          and issued an FAQ to clarify
                         0% as of 2 April.                                                                                                                          details of the ban.
                         July 28: ACPR called on financial                                                                                                          May 18: AMF suspended the ban
                         institutions to follow the ESRB’s                                                                                                          on the creation or increase of net
                         recommendations on                                                                                                                         short positions.
                         distributions of dividends,
                         variable compensation, and share
                         buybacks.

                                          2021
                         February 18: ACPR requested
                         financial institutions remain very
                         cautious with regard to
                         distributions (dividends, share
                         buybacks, variable compensation)
                         until September 30, 2021.
                         October 1: ACPR confirmed to lift
                         its recommendation on
                         distributions (dividends, share
                         buybacks, variable
                         compensation).
Germany                                        2020                                             2020                 2020                         2020                            2020

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Provisioning, Definition of
                                                                                                                                                                  Consultations/                         Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                   Default and NPL-related
                                                                                                                                                             Implementation Timetables                    testing, conduct, etc.)
                                                                                                                                 measures
                         March 18: Deutsche Bundesbank                          March 20: BaFin announced in its       March 27: BaFin and Deutsche         April 2: BaFin and Deutsche              March 19: BaFin clarified the
                         announced that BaFin intends to                        FAQs that liquidity buffers can be     Bundesbank shared the view that      Bundesbank postponed the stress          scope of prohibitions on short-
                         lower the countercyclical capital                      used without any approval of the       the current situation does not       test for less-significant institutions   selling.
                         buffer from 0.25% to 0% as of                          supervisors in the current stress      lead to an undifferentiated,         planned for 2021 to 2022.
                         April 1.                                               situation as foreseen in the           automatic transfer of financial
                         March 24: BaFin recommends                             regulation.                            instruments from Level 1 to Level
                         firms pause share buybacks and                                                                2 or Stage 3.
                         carefully consider dividends and
                         bonuses.
                         March 30: BaFin confirmed that
                         they expect banks to not pay any
                         dividends or distribute profits
                         until at least October 2020.
                         March 31: BaFin issued a general
                         order to reduce the quota for
                         domestic countercyclical capital
                         buffer from 0.25 percent to 0
                         percent as of April 1.
                         August 4: BaFin reiterated its
                         position on dividend payments.
                         September 21: BaFin will let less
                         significant institutions under its
                         supervision exclude certain
                         exposures to central banks from
                         the leverage ratio.
Hong Kong                               2020                                                    2020                                    2020                                 2020                                  2020
                         March 16: HKMA lowered the                             April 3: HKMA announced                March 30: HKMA announced that        March 30: HKMA said it would             April 7: HKMA issued a letter on
                         counter-cyclical buffer level from                     measures to increase the banking       it is in discussions with relevant   defer Basel III implementation in        AML/CFT measures during COVID-
                         2.0% to 1.0% to support banks in                       sector’s liquidity and encouraged      bodies about the application of      line with BCBS’s updates.                19.
                                                                                banks to use their liquidity buffers   expected credit loss provisioning

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                                      Page 28
Provisioning, Definition of
                                                                                                                                                                  Consultations/                      Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                   Default and NPL-related
                                                                                                                                                             Implementation Timetables                 testing, conduct, etc.)
                                                                                                                                 measures
                         extending credit facilities to                         even if their LCRs fall below the      requirements and expects to          March 31: SFC said it is extending    April 21: SFC released a statement
                         customers.                                             requirement.                           make a further announcement          the implementation deadlines of       on its commitment to providing
                         July 7: HKMA announced that the                        April 3: HKMA said the current         soon.                                certain intermediary regulations.     regulatory relief during COVID-19.
                         countercyclical capital buffer                         level of regulatory reserves will be   April 8: HKMA decided to lower       May 7: SFC will postpone the          April 22: HKMA decided to
                         remains unchanged at 1.0%.                             reduced by half.                       the regulatory reserve               implementation of initial margin      postpone the 2020 Supervisor-
                         October 12: HKMA announced                                                                    requirement used for provisioning    requirements for non-centrally        Driven Stress Test until 2021.
                         that the countercyclical capital                                                              by 50% with immediate effect.        cleared over-the-counter
                         buffer remains unchanged at 1%.                                                               May 25: HKMA clarified its           derivative transactions by one
                                                                                                                       expectation on treatment of          year, in line with IOSCO and BCBS.
                                        2021                                                                           expected credit loss provisioning.   May 25: HKMA will defer the final
                         January 28: HKMA announced                                                                                                         two implementation phases of
                         that the countercyclical capital                                                                                                   margin requirements for non-
                         buffer will remain unchanged at                                                                                                    centrally cleared OTC derivatives
                         1%.                                                                                                                                by an additional year until 1
                         May 17: HKMA announced that                                                                                                        September 2022.
                         the countercyclical capital buffer
                         will remain unchanged at 1%.                                                                                                                      2021
                         August 5: HKMA announced that                                                                                                      June 10: HKMA announced
                         the countercyclical capital buffer                                                                                                 revision to Basel III
                         will remain unchanged at 1%.                                                                                                       implementation timeline.
                         October 28: HKMA announced
                         that the countercyclical capital
                         buffer will remain unchanged at
                         1%.
India                                    2020                                                 2020                                    2020                                  2020                                  2020
                         March 27: Reserve Bank of India                        March 27: Reserve Bank of India        April 17: Reserve Bank of India      April 17: Reserve Bank of India       March 20: SEBI announced
                         decided to maintain current                            decided to defer the                   permitted to grant a moratorium      outlined detailed instructions        regulatory measures including
                         minimum capital conservation                           implementation of the Net Stable       of three months on payment of all    relating to extension of resolution   position limits on stocks and
                         ratios until September 30 with the                     Funding Ratio to October 1.            term loan instalments falling due    timelines.                            derivatives.
                         last tranche of the capital                                                                   between March 1 and May 31 and

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