With reference to Regulatory Roundup 36 concerning the final rules to implement CRD 3, a reminder that the Pillar 3 disclosure obligations in BIPRU 11 are to be enhanced with effect from 31 December 2011 (a typo in the last edition showed the date as 2012).
BIPRU 11.3.3(2) will be added requiring a firm to have policies for “.. assessing whether its disclosures convey its risk profile comprehensively to market participants”. Where it is concluded that the disclosures do not achieve this requirement then the firm must publicly disclose the necessary information.
BIPRU 11.5 will impose greater disclosure obligations in respect of securitisations and market risk where these are applicable.
The rule changes can be seen in Appendix 1 of PS11/12.
On the matter of implementing CRD 3 it is interesting to note from a press release that since the last Regulatory Roundup the Commission is to bring Italy and Poland before the Court of Justice for incomplete transposition of CRD 3. The penalty payments requested are €96,446.70 per day and €37,396.80 per day respectively.
