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A banking expert criticizes weak government support to the banking sector

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A banking expert criticizes weak government support to the banking sector Empty A banking expert criticizes weak government support to the banking sector

Post by claud39 Thu Dec 13, 2018 9:54 am

http://economy-news.net/content.php?id=14736


A banking expert criticizes weak government support to the banking sector


12/13/2018


A banking expert criticizes weak government support to the banking sector 11836



Economy News Baghdad:



The banking and economic expert, Samir Nusairi, criticized the weakness of government support to the banking sector, which contributed to the delay in the growth of the banking sector.
"The suffering of the Iraqi banking sector, especially private banks in all areas of its banking activity, due to the weak government support provided to it, although it has already been That several decisions were issued by the Economic Affairs Committee of the Council of Ministers, stressing the obligation of the parties concerned to provide support to banks.
Al-Nusairi stressed that weak follow-up by those responsible for the implementation of government decisions such as the Ministry of Finance obligate all state departments to accept the ratified instruments issued by private banks and to confirm the activation of the role of the Financial Court as provided by the Banking Law and in accordance with the law of the Central Bank of Iraq, Other " .
He added that the shortcomings in the structure of bank financing in Iraq is the result of continued weak contribution of cash and credit granted to the gross domestic product to not exceed 16.8% while in the regional countries (Middle East and North Africa up to 55%).
He pointed out that the developments in the banking sector during the last four years are the commitment and work in accordance with the controls issued by the Central Bank of Iraq on combating money laundering and financing of terrorism derived from FATF recommendations and in light of the bases derived from the Iraqi Anti Money Laundering Law No. 39 For the year 2015 .
He continued to abide by the regulatory directives developed by the Central Bank in cooperation with the International Fund's Metac Center and to make them conform to international standards and the requirements of Basel III. And the transformation in the preparation of final and interim statements to international standards (IFRS), which ensures transparency of data and dealing with it by all parties responsible for financial reporting .
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A banking expert criticizes weak government support to the banking sector Empty The Middle East Regional Technical Assistance Center

Post by claud39 Thu Dec 13, 2018 9:58 am

https://www.imf.org/external/np/exr/facts/fre/afritacf.htm



The Middle East Regional Technical Assistance Center



The Middle East Technical Assistance Center (METAC)was established in Beirut (Lebanon) in 2004 to serve ten countries / territories in the Middle East (Afghanistan, West Bank and Gaza Strip, Egypt, Iraq, Jordan, Lebanon, Libya, Sudan, Syria and Yemen). The mission of METAC is mainly to contribute to strengthening the capacity of countries in the region to ensure effective macroeconomic and financial management, as well as to support the integration of the region into the global economy. METAC is particularly concerned with helping the post-conflict countries of the region achieve economic stability and establish the basic institutions necessary for the conduct of economic policy. The METAC was designed to strengthen the coordination of the activities of the various development partners and to promote the effective implementation of economic programs in the Middle East. Its current program cycle is financed by contributions from Germany, the European Investment Bank, the United States, the IMF, France, Kuwait, Oman, the European Union, the country host country (Lebanon) and beneficiary countries.
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A banking expert criticizes weak government support to the banking sector Empty Basel III: enhanced solvency of banks

Post by claud39 Thu Dec 13, 2018 10:16 am

http://www.revue-banque.fr/risques-reglementations/article/bale-iii-une-solvabilite-renforcee-des-banques


Basel III: enhanced solvency of banks




The 15/12/2010



While Basel II had focused heavily on the calculation of the risks in the denominator of the solvency ratio, Basel III is tackling its numerator: equity. The Committee has thus planned a hardening, both quantitatively and qualitatively, of their calculation, via a complex system of deductions.




The Basel Committee, through the guidelines set by the G20, aims by its Basel III reform to "  improve the resilience of the banking sector, that is to say its ability to absorb shocks in times of financial stress and economic, whatever the source . " To achieve this goal, it will define new solvency rules designed to strengthen banks' own funds, both in terms of quality and quantity [1] .
The three axes of the Committee
Three complementary objectives should help prevent a new financial crisis. Strengthening the quality of banks' capital, first of all. The Basel II reform had significantly modified the capital requirements calculations (denominator of solvency ratios), ie the calculation of risks generated by banking activities. The numerator components of these ratios, on the other hand, remained heterogeneous across countries. It should be remembered that Basel II will remain valid for most risk measures, with the exception of market activities, and that the Basel III regulation is thus superimposed on the latter by enriching it. Some securities classified as hard equity have not absorbed enough losses during the recent crisis, notably preference sharesAnglo-Saxon countries. This situation has, in a way, accelerated the harmonization movement and the inclusion criteria have been tightened on all the equity compartments.
More deductions from own funds were also decided. Several complaints had been made to the prudential regulation concerning certain unfair capital elements:

  • minority interests could only cover the risks of the subsidiaries concerned;
  • the treatment of bank-type holdings (deducted up to 50% of Tier 1) and insurance could lead to a form of double counting of own funds that had to be eliminated, even if the subject had already been partly apprehended by Basel II for investment in banks and fully regulated in Europe, by the directive on financial conglomerates, for investments in insurance.

Last but not least (and in addition to the increased requirements on market activities already mentioned), the Basel Committee has provided for a strengthening of the amount of capital of banks, setting levels of solvency ratios very significantly higher .
Strengthening the quality of equity
Common Equity Tier 1
The Basel Committee introduces a new concept of capital into prudential regulation: the common equity Tier 1 or CET1.
This new level of capital will cover the strongest form of equity and is expected to focus a significant portion of analysts 'and investors' attention. In total, three notions of equity will be referred to risk ("risk weighted assets") and will give three levels of ratios: the CET1 ratio, the Tier 1 ratio and the Global ratio.
A similar "Core Tier 1" concept already exists in financial communication of financial institutions, but without a clear regulatory basis. It is a concept that has been developed by and for the markets, but which has been applied in a non-coherent and non-harmonized manner by the banks (the English institutions have thus included, for example, their preference shares ) and which has proved ultimately irrelevant. She will disappear very quickly.
The CET1 will replace it, now with fourteen official and precise criteria for defining the instruments in this highest category of capital. These criteria essentially describe the characteristics associated with ordinary shares and aim to ensure all the qualities sought for this type of purest capital: the "  permanence " of equity, the "  flexibility of payments " attached to it and "the ability to to absorb losses "in all circumstances.
The titles of cooperative or mutual banks have also been formally recognized as part of the CET1, in their various current French forms (shares, partnership certificates and investment certificates).
Finally, minority interests are finally permitted, but under certain conditions ( see below ).
Note that equity instruments that do not meet the new criteria for inclusion in the Common Equity Tier 1 will be excluded from this category as of 1 st January 2013. However, instruments that meet the following three conditions will be phased out in 10 years horizon , according to the schedule described above:

  • Issuance by a corporation other than a corporation;
  • recognition as capital ( equity ) according to the accounting standards in force;
  • taken into account without restriction in Tier 1 under the banking legislation in force.

The lower tier 1
Fourteen other criteria define the securities eligible for lower tier 1, now also known as "Tier 1 additional going concern capital ".
Admission conditions have been tightened and even hybrid securities issued by French banks - which are among the best in the market as capital - can not meet all these criteria.
Two criteria improving the absorption of losses will indeed require adaptations (relatively expensive) for their future emissions:

  • Criterion 4, which eliminates de facto any stock with step up (instrument named to date as an innovative lower tier 1): the instrument must be perpetual, that is to say without maturity date and without incentive for reimbursement, the reimbursement incentive being defined by the regulatory authorities as the combination of a step-up (increase) in the interest rate and a call (early repayment option) exercisable on the same date;
  • Criterion 7 (a) " Does the bank have the possibility to cancel instrument payments at any time? Is aimed at prohibiting the application of the pusher dividend mechanisms , that is to say the mechanisms by which, in continuity of activity, the payment of a dividend by the bank entails automatically and compulsorily the payment of a coupon on the hybrid title. Like most existing Tier 1 markets, the French banks' contracts all contain a pusher dividendwhich relates to the payment of a dividend on the Common Shares or paid to a stock of the same rank (and also on other payments such as share repurchases). It should be noted that in December 2009, the Committee of European Banking Supervisors (CEBS) defined criteria for taking into account these push-back dividends and that the project discussed in the Basel Committee has thus become more restrictive in this respect.

French lower tier 1 securities , as in other countries, will not be Basel III compliant, but will be subject to a grandfathering clause ( see below ).
The result of the new Basel III rules will also lead to an increase in loss-absorbing capacity, regardless of the accounting classification of the instruments, the treatment in equity as opposed to "debts" allowing in many cases in Basel II (for example, Anglo-Saxon preference shares ).
Tier 2
The Tier 2 objective corresponds, in the Basel philosophy, to the absorption of losses on the basis of the so-called "  gone concern " (period just before a possible liquidation), as opposed to the notion of "  going concern " (in continuity with exercise) which particularly affects the Tier 1 components. Part of the current Tier 2 capital of French banks will be eligible for the (ten) criteria defined by the Basel Committee in December 2009. However, will be declassified, as on the Tier 2. 1, all instruments that include an incentive to repay, which is always defined by the combination of a step-up of the interest rate and a callexercisable on the same date. The possibility, strictly supervised in France by the ACP, to issue hybrid instruments that may include a step-up, provided that the level of pay jumps does not exceed a level of 100 basis points or a level of 50% of the initial line of credit disappears as well. Finally, to be fully eligible Basel III, a title / loan must be repayable at the initiative of the issuer / borrower and only after a minimum period of five years after its issuance / availability.
Absorption capacity of losses
In addition, the Basel Committee published an advisory paper in August 2010 outlining proposals to increase the ability to absorb regulatory capital losses in the event of a bank failure ("Proposal to Ensure the Loss Absorbency"). Regulatory Capital at the Point of Non-Viability ").
The Basel Committee's criteria may thus not be definitive since they are 15 th (for Lower Tier 1) and 11 th (for Tier 2), known as loss absorption with conversion to CET1 or write off could complete the December 2009 feature.
Grandfathering on Tier 1 and Tier 2 hybrid titles
grandfathering clause will be put in place to allow for a phase of gradual adaptation of banks to these new criteria: all securities that are not eligible under Basel III, ie capital instruments currently taken into account Basel II, but does not meet the new definition of hybrid Tier 1 or Tier 2, will be an outstanding stock on 1 st January 2013 which will be amortized linearly over 10 years (note that this time, even if it allows time to adapt to it, it is finally shorter than the grandfathering phases included in the European CRD 2 at the end of 2010). Taking as a basis the nominal outstanding amount of these instruments at 1 stJanuary 2013, their prudential recognition will be limited to 90% as of 2013 and then this ceiling will be reduced annually by 10% ( see Chart 1 ).
All new issues will have to comply with the 14 (15?) Criteria of the December 2009 Basel Committee for Tier 1 and 10 (11?) For Tier 2.
An increase in deductions
This second component of strengthening the quality of banks' own funds covers two types of measures:

  • As the new CET1 is a combination of positive and negative elements, the number of negative elements will be significantly higher tomorrow compared to the current Basel II situation, thereby decreasing the numerator of the solvency ratio. The (French) equivalent of CET1 included only two deductions: goodwill and intangible items. The Basel Committee will add several types of deductions described below;
  • under Basel III, all deductions will apply in full on CET1. So far under Basel II, the deductions were mixed, 50% in Tier 1 and 50% in Tier 2, and therefore with less impact.

CET1 thus covers three positive elements: capital, in the form of ordinary shares or securities of cooperative or mutual banks; the reserves and the retained result; and a portion ( see below ) of minority interests. Many, most of which are new, will now be deducted from equity and will reduce the final CET1 amount. These include investments in banks, investments in insurance, deferred tax losses, deferred taxes such as timing differences , mortgage servicing rights (MSR) and several other deductions listed. thereafter.
The first elements of deductions are the most sensitive for French banks and they will therefore be more particularly described. It should be noted that the MSR, that is to say the transferable administrative charges related to mortgages, is not a subject for French banks.
Investments in banks
Investments made by banks in other banking securities are probably one of the most complex areas of Basel prudential regulation. In fact, they focus on many sensitive points: on the one hand, the (legitimate) concern of regulators to avoid a systemic risk linked to holdings between banks that could artificially create "  double counting of own fundsIn the financial system. On the other hand, multi-faceted consolidation accounting standards: global consolidation, proportional consolidation, equity accounting, minority shareholdings. And finally, the "materiality" of investments that led regulators to distinguish holdings of more than 10% in the bank concerned by investment and holdings of 10% or less.
These categories result in different treatments:
[list="font-weight: 400; margin-right: 0px; margin-left: 0px; padding-right: 0px; padding-left: 0px;"]
[*]fully consolidated investments, possibly with the presence of minority interests;
[*]proportionately consolidated holdings , which should disappear rapidly;
[*]investments accounted for using the equity method , requiring "  significant influence " in the management of the bank concerned, and which result in the recognition of the historical value, the recognition of a possible goodwill and possibly a provision for securities;
[*]minority holdings held at more than 10% (portfolio available for sale ), valued on a mark-to-market basis and which generally record these changes in value in equity (except for long-term depreciation). The existence of a new Prudential Franchise (shown here with a capital letter to distinguish it from the small deductible in the following paragraph) will make it possible to exempt from deduction, to a certain extent, the two previous types of shareholdings.
[*]holdings held less than 10% , benefiting from a "small" franchise (this rule is included in the European texts since Basel II and is now taken over by the Basel Committee) up to 10% of CET1. These more minor participations will be, in most cases, almost free of deductions;
[*]bank securities held in trading portfolios , with the possibility of offsetting between long and short positions on the same issuer;
[*]other investments in institutions (cross-shareholdings) not subject to the threshold below.
[/list]
The Basel Committee's December 2009 proposal states that  "(i) if a bank holds common shares in other institutions and its holding represents more than 10% of its common shares, then it will have to deduct from its own funds own the total amount of the participation; and (ii) if a bank holds common shares in other institutions and all such holdings represent more than 10% of its own common shares, then it will have to deduct from its own funds an amount in excess of 10% of its own shares. % ". The following are covered: cases 3, 4 and 6 above.
Cases 1 and 2 thus refer to the treatment of minority interests on the liabilities side of the consolidated balance sheet examined below. Case 5 is, as already stated, the subject of a proper franchise. Finally, for case 7, the deduction is systematic.
Investments in banks holding more than 10% and equity-accounted investments thus enjoy a new regulated regime. The heaviest investments will continue to be consolidated globally and the lowest will be taken into account in weighted jobs.
In case of non-deduction, the bank will not be spared any capital requirements. The treatment that will apply then corresponds to the treatment of the elements composing the Franchise.
Also noteworthy, as another mechanism for deducting dividends in financial institutions: capital instruments issued by financial institutions will be deducted from their category - CET1 vs. CET1, Lower Tier 1 vs. Lower Tier 1 and Tier 2 vs. Tier 2.
Investments in insurance
The investments in insurance companies have not been the subject of a thorough analysis by the Basel Committee. This point of supervision, delicate and complex, is generally covered by an international body comprising both bank regulators, insurance regulators and securities regulators ( Securities ) and the work is done within a trading platform called the Joint Forum. Conclusions were defined more than 10 years ago and updated in 2009.
Bancassurance activities are more particularly developed in Europe, and particularly in France. This is why the implementation of the rules of this Joint Forum has been much faster and more advanced on our European continent, in particular through the 2002 conglomerates directive. For several years, therefore, there has been more regulation. advanced in Europe, especially in terms of internal control and major risks, but also solvency ratios, since a supplementary ratio called observation is for example regularly produced by French banks with significant insurance subsidiary (s) (s) ( see Box 1). In their final version - a derogation was granted until 2013 to allow a gradual implementation of the constraints related to this European directive on conglomerates - these rules avoid precisely double counting of capital between banks and insurance companies.
It seems likely that Europe will preserve this regulatory advance. The deduction will be based, following the French transposition of the European conglomerates directive, on the difference in the equity method (deducted at 100% CET1) and the VME-DMEdifferential [2] should be treated in weighted positions like any outstanding amount. shares of the banking book . And, as for bank participations, the Tier 1 and Tier 2 insurance subsidiaries will be re-evaluated in accordance with banking regulations and deducted respectively from Tier 1 and Tier 2.
Minority interests
The "minority interests" represent in accounting the investors in ordinary shares outside the group who are present in subsidiaries of this banking group. They only appear in the case of consolidated subsidiaries. The Committee will finally allow a "conservative" consideration of minority interests covering the risks of a banking subsidiary (the original text of December 2009 excluded any consideration). Equity held by the subsidiary above a minimum level of requirement will no longer be recognized in the CET1 and will be deducted proportionately (or "clipped") from the minority interest.
It should be noted that the European rules extend the notion of a banking subsidiary to regulated entities: it is therefore likely that this treatment will include, as today, any entity supervised by the banking regulator (including asset management).
Several uncertainties remain as to the details of the inclusion of these minority interests in the CET1. For example, goodwill should be included in the calculation methods to avoid any "double jeopardy" for banks, due to consideration at the sole level of the subsidiary and consolidated level of the group. The intragroup should be included in the risks considered. The issue of new IFRS 28 needs to be addressed. Doubts also remain about the minimum level of requirement to be applied to the percentage of weighted jobs (minimum level of pillar 1?, Actual level of pillar 1?, Pillar 2?). The recognition of minority interests should be different for CET1, Tier 1 and the Global ratio.
Deferred tax assets (deffered tax assets)
Despite comments from the banking profession, deferred tax assets will not be considered by regulators as real equity. At the very least, it will be possible to reason in net terms (deferred tax assets - deferred tax liabilities). DTAs of the "loss carry forward" type will be deducted from CET1. Deferred tax assets resulting from temporary differences (general or collective provisions, deferred bonuses, etc.) will also be deducted from CET1, but only when they exceed the Franchise set by the regulations.
Other deductions
Other deductions from CET1 have been made:

  • goodwill ( goodwill ) and other intangible assets (excluding MSR), as is already the case in Basel II;
  • own shares held, this point remaining outstanding for trading positions ;
  • the shortfall of the provision  of expected losses , which will go from a Tier 1 deduction in Basel II to CET1 [3] in Basel III.
  • reserve for cash flow hedge ( cash flow hedge accounting reserve );
  • cumulative changes in own credit risk ("  cumulative gains and losses due to own credit risk on financial assets") and pension assets ("  defined benefit pension funds and liabilities ");
  • non-investment grade CDOs which will now be systematically treated in weighted positions. In Basel II, two treatments were possible: that of a deduction at 50% of Tier 1 and at 50% of Tier 2, and the one - which alone will therefore remain - of a risk-weighted treatment;
  • Prudential filters on capital gains and losses: today, the Basel Committee's response to the questions of the profession is: " The Committee will continue to review the issues as unrealized earnings are concerned ". It will thus be necessary to wait for the evolution of the accounting rules, in particular the new IFRS 9 standards, for a final decision in this area.

The transition phase
In the summer of 2010, two measures of the Basel Committee mitigated somewhat the Basel III impacts: one is perennial, the Franchise scheme (see Box 2); the other is intended to provide a (long) transitional period. National implementation by member countries will start on 1 January 2013. They will have to have implemented these rules into their respective laws and regulations before that date. The Basel Committee has introduced a significant transition phase in this implementation of the deductions. Regulatory adjustments (deductions and prudential filters), and in particular amounts beyond the deductible for investments in other financial institutions, MSRs and DTAs, will not be fully deducted until 1 January 2018 CET1 .
More concretely, the regulatory adjustments will be deducted up to 20% on 1 st January 2014, and then increase to 40% on 1 stJanuary 2015 to 60% on 1 st January 2016 to 80% on 1 st January 2017 to reach these 100% on 1 st January 2018 ( see Figure 2). During this transition period, the undeducted portion of this component will continue to be subject to national treatment. Deductions with the Franchise system will thus be progressive between 2013 and 2018 (percentage increasing by 20% each year). In a given year, if 40% of the deduction and the Basel III Franchise are applied, then, on these same transactions, the banks will have to take 60% of the Basel II charge.
Ratio target levels

Last but not least - the minimum capital requirements will be significantly increased. Here again with a transition period in the implementation. The CET1 will be raised from its current level of 2% to 4.5%, and this after applying the new deductions more stringent, as indicated above. This increase will be gradual, however, until 1 st January 2015. The requirements in Tier 1 capital will be increased from 4% to 6% over the same period.
A conservation buffer, which will be added to the minimum regulatory requirements, will be set at 2.5% and also made up of CET1. The purpose of this drive will be to ensure that banks have a "mattress" to cope with periods of economic and financial difficulties. Banks will be able to use this mattress in times of stress, but the more they choose to stay close to regulatory minimum ratios, the more they will be subject to strong profit distribution constraints. This conservation buffer capital will be phased in between 1 st January 2016 and the end of 2018, to become fully effective on 1 st January 2019. Its gradual implementation will begin on 1 stJanuary 2016 a requirement of 0.625% of the weighted assets risk, which will be increased by 0.625% each year until the 1 stJanuary 2019, the final level of 2.5%. Countries that experience excessive credit expansion, if any, should consider speeding up the constitution of this conservation buffer and the counter-cyclical buffer. National authorities, which will be free to impose shorter transitional periods, will have to consider it if necessary. Banks meeting the minimum capital ratio during the transition period but remaining below the 7% target for the CET1 ratio (minimum ratio + conservation buffer) will have to follow prudent profit distribution policies in order to constitute a steering wheel. as soon as reasonably practicable.
In addition, the banks could be imposed three additional constraints, but at this stage little formalized, let alone economically realistic:


  • a counter-cyclical buffer, ranging from 0% to 2.5% and composed of CET1 elements, "  depending on national economic conditions ";



  • a need related to a potential Tier 1 deficit of a new leverage ratio that could complement risk-based solvency ratios;



  • and a layer of additional capital for institutions that the Financial Stability Board will deem to be "  systemically important ".


Points still outstanding
There are still several unknowns in the calculation of new capital requirements: level of clipping of minority interests, treatment of items entering the new franchise, whether or not capital gains are taken into account ( see Box 3 ). etc. These currently prevent any very precise assessment of Basel III impacts for banks. A continuation of the conglomerates directive is also widely desired to correct the imperfections of the Basel text.
More generally, this reform will require de facto for banks, failing to increase their capital, to release recurrent results and put them in reserve. It will have an impact on the cost of banking services and their profitability, and therefore on the attractiveness of the sector compared to other industries.
Finally, one of the important issues of this reform will be the equality of competition at world level, with the question: will US banks implement Basel III even though they have never implemented Basel II? The answer will be crucial for the new global economic and financial context that is being built.

[1]The innovations introduced are still being formalized at the time of writing this article (with a target date set for December 2010 for the Basel Committee and March 2011 for the first draft of the resulting European CRD 4 Directive). It should be emphasized that the new measures described below are still conditional. In some cases, excerpts from official texts have been included to avoid over-interpretation.
[2]Equity value - difference in the equity method.
[3]Conversely, the excess of the provision over the expected loss will continue to be included in Tier 2 (where appropriate with a limit of 0.6% of weighted positions under review).
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A banking expert criticizes weak government support to the banking sector Empty IRFS

Post by claud39 Thu Dec 13, 2018 10:40 am

https://www.ifrs.org/about-us/who-we-are/


A banking expert criticizes weak government support to the banking sector Ifrs-logo2



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The IFRS Foundation is a not-for-profit, public interest organisation established to develop a single set of high-quality, understandable, enforceable and globally accepted accounting standards—IFRS Standards—and to promote and facilitate adoption of the standards.
IFRS Standards are set by the IFRS Foundation’s standard-setting body, the International Accounting Standards Board.
Find out more about the structure of the IFRS Foundation and our consultative bodies.

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Our mission is to develop IFRS Standards that bring transparency, accountability and efficiency to financial markets around the world. Our work serves the public interest by fostering trust, growth and long-term financial stability in the global economy.

  • IFRS Standards bring transparency by enhancing the international comparability and quality of financial information, enabling investors and other market participants to make informed economic decisions.
  • IFRS Standards strengthen accountability by reducing the information gap between the providers of capital and the people to whom they have entrusted their money. Our Standards provide information needed to hold management to account. As a source of globally comparable information, IFRS Standards are also of vital importance to regulators around the world.
  • IFRS Standards contribute to economic efficiency by helping investors to identify opportunities and risks across the world, thus improving capital allocation. Use of a single, trusted accounting language lowers the cost of capital and reduces international reporting costs for businesses.

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IFRS Standards are currently required in more than 140 jurisdictions and permitted in many more. Find out more about the use of IFRS Standards around the world here.
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A banking expert criticizes weak government support to the banking sector Empty Controls of capital adequacy standard in accordance with Basel II requirements

Post by claud39 Thu Dec 13, 2018 1:42 pm

https://cbi.iq/news/view/930


Controls of capital adequacy standard in accordance with Basel II requirements




November 18, 2018



A banking expert criticizes weak government support to the banking sector News-154252812862111







To all licensed commercial banks ( the capital adequacy adequacy controls in accordance with the Basel III requirements ) ... Click here to download



https://cbi.iq/static/uploads/up/file-154252811462306.pdf
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