What we heard: consultation on draft amendments to Pillar 3 Disclosure Guidelines on Crypto-asset Exposures
| Theme | Stakeholder feedback | Our response |
|---|---|---|
|
Materiality |
Respondents consider the principles-based approach to materiality for individual crypto-assets in template CAE1 to meet the disclosures objectives and information needs of market participants and users. |
We have not introduced quantitative materiality thresholds in template CAE1. We expect deposit-taking institutions in scope to apply the principles in the Pillar 3 guidelines to assess the materiality of crypto-assets. |
|
Daily averages |
Most respondents consider daily averages in addition to period-end exposures would not provide meaningful information. Other respondents consider daily averages would be meaningful in the context of supervisory activities and of certain specific products. |
We have not introduced disclosure of daily averages in template CAE1. We expect deposit-taking institutions in scope to disclose period-end values only. Supervisors have access to more information than public disclosures to support supervisory activities. |
|
Liquidity |
Most respondents indicated that the granularity in template CAE3 is not commensurate with the level of risk and likely to introduce undue burden. Other respondents consider template CAE3 would be appropriate for supervisory activities. |
We have not included template CAE3 in our guidelines. We expect deposit-taking institutions in scope to discuss liquidity risks in table CAEA and to include crypto-assets in the LIQ Pillar 3 templates. Supervisors have access to more information than public disclosures to support supervisory activities. |
|
Proportionality |
Most respondents consider the proposed disclosures for SMSBs are appropriate. Other respondents favor the same disclosures as D-SIBs given crypto-assets are less mature. |
No changes have been made from the disclosures for SMSBs proposed during the consultation, which is consistent with our Pillar 3 approach to ensure disclosures appropriately reflect the SMSBs’ risk profile, nature, size, and complexity. |
|
Other comments |
Some respondents provided comments beyond the scope of our consultation, such as support for measures to help Canadians improve their digital and financial literacy or for the regulation of the use and issuance of fiat-referenced crypto-assets. |
We consider these comments out of scope for purposes of the Pillar 3 guidelines. We have considered all relevant comments to establish crypto-asset disclosure expectations that are appropriate for deposit-taking institutions. |