The Communiqué on Risk Management Disclosure By Banks was
published in Official Gazette number 29511 on 23 October 2015
("Communiqué"), coming in force
on 31 March 2016. The Communiqué outlines procedures and
principles of consolidated and unconsolidated risk management
disclosure to be made by banks. It also includes obligatory tables
and templates in this regard. It represents a more compatible
regulatory structure with the Basel standards than previously
existed in Turkey.
The Basel Committee on Banking Supervision ("Basel
Committee") frames general bank supervision and
regulation worldwide. The Communiqué introduces amendments
to align Turkish regulation with the standardized approach
introduced in 2012 by the Basel Committee's Regulatory
Consistency Assessment Programme, particularly the Third Basel
Accord (Basel III). Basel III was issued to prevent insufficiency
of liquidity caused by risky loans. Member states are expected to
harmonize domestic law with Basel III provisions by 31 March
According to the Communique, any information regarding risk
management must be included in financial reports as a separate
section. Disclosures must be easily accessible and must enable
measurement and assessment of information given by banks.
Furthermore, banks must keep an online disclosure database, showing
five years' worth of records. The online database must be
available on a bank's website from 31 March 2016 onward.
The Communiqué also includes format and frequency of
report tables and report templates for disclosures (Attachment No:
1). These disclosure reports are subject to internal auditing and
examination as financial reports.
Banks can refuse to share information if risk management
disclosures contain information that could be regarded as business
secrets. In these circumstances, banks should state in an
additional part of the disclosure report that they have not
disclosed the relevant information and the reasons for this
The Communiqué outlines principles for transparent and
good quality risk management disclosures. Accordingly, disclosures
In due course and consistent.
Comparable with other banks.
Comprehensible and accessible.
Important information should be highlighted and complex subjects
must be explained in plain language.
If risk exposure is insignificant or tables and templates are
incomprehensible, banks may choose to not to reveal such
information, provided they explain this in the additional
information part of the disclosure report.
Disclosures made within the scope of the Communique are subject
to independent audit.
Please see this link for the full text of the
Communiqué (only available in Turkish).
Information first published in the
MA | Gazette, a fortnightly legal update newsletter produced by
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