Committee-Level Communications
Committee-level Communications are those letters and other documents developed by working groups of Association Committees, commonly covering technical topics in the context of urgent regulatory consultations. These communications enable streamlined attention to time-critical circumstances without requiring formal Association approval procedures.
In view of the narrow focus of these communications and the attention given to them by Association member bank experts, the Association selects to post on its website those documents that may be of general public/industry interest. As each such document notes, these communications are subject to supplemental commentary over time, including via formal Association Commentary.
Americas
Joint Trade Letter to the Chair, President’s Working Group on Digital Asset Markets, February 20, 2025
Joint Trade Letter to the Federal Deposit Insurance Corporation regarding the Notice of Proposed Rulemaking on Recordkeeping for Custodial Accounts, January 16, 2025
Comment Letter regarding the U.S. Agencies Financial Data Transparency Act Joint Data Standards Proposal, October 21, 2024
Joint Trade Letter regarding Financial Data Transparency Act Joint Data Standards Proposal, October 8, 2024
Letter to the SEC, regarding the T+1 Transition Date, February 11, 2023
Joint Association Letter to the SEC, regarding the T+1 Transition Date, October 10, 2022
Letter to the Office of the Comptroller of the Currency, regarding OCC Advanced Notice of Proposed Rulemaking, Fiduciary Capacity, Non-Fiduciary Custody Activities, 84 FR 17967 (April 29, 2019, June 28, 2019
Letter to Christopher Kirkpatrick, Commodity Futures Trading Commission, regarding De Minimis Exception to the Swap Dealer Definition 83 Fed. Reg. 27444 (June 12, 2018), RIN 3038-AE68 and Non-Deliverable FX Forwards, August 10, 2018
Letter to William Coen, Basel Committee on Banking Supervision, Bank for International Settlements, regarding Comments on Basel Committee's Consultative Document on Global Systemically Important Banks - Revised Assessment Framework, June 30, 2017
Asia
Consultation Paper on the Introduction of Optional T+0 and Optional Instant Settlement of Trades in Addition to T+1 Settlement Cycle in Indian Securities Markets, January 17, 2024
Letter to the Securities and Exchange Board of India regarding Consultation Paper on the Introduction of Optional T+0 and Optional Instant Settlement of Trades in Addition to T+1 Settlement Cycle in Indian Securities Markets, January 17, 2024
Letter to the Securities and Exchange Board of India regarding Introduction of Optional T+0 and Instant Settlement of Trades, January 11, 2024
Letter to the Securities and Exchange Board of India, regarding Standard Operating Procedure (SOP) for Seeking Additional Disclosures from Certain Foreign Portfolio Investors (FPIs), December 18, 2023
Letter to the State Securities Commission of Vietnam regarding AGC Member Banks’ Concerns regarding the Implementation of the Central Counterparty Clearing House in Vietnam, June 28,2023
Letter to the Securities and Exchange Board of India, regarding Identification and Verification of Beneficial Owners of Foreign Portfolio Investors, August 21, 2023
Letter to Dr. Sethaput Suthiwartnarueput, Governor of the Bank of Thailand, regarding Non-resident Qualified Institution (NRQI) and Non-resident Baht Account for Securities (NRBS) Accounts, June 14, 2023
Letter to Dr. Pakorn Peetathawatchai, The Stock Exchange of Thailand, regarding Corporate Actions Announcements - Standardization, June 12, 2023
Letter to The Honorable Smt Madhabi Puri Buch, Securities Exchange Board of India, regarding the Successful Implementation of T+1 Settlement in India, May 8, 2023
Letter to the Securities and Exchange Board of India, regarding T+1 Settlement for Foreign Portfolio Investors, November 8, 2022
Joint Communication of the AGC Asia Focus Committee and ICI Global to the Minister of Finance in India regarding Introduction of T+1 Rolling Settlement in India's Equity Markets, December 9, 2021
Letter to the Securities and Exchange Board of India regarding Introduction of T+1 rolling settlement on an optional basis, September 24, 2021
Letter to the Securities and Exchange Board of India regarding Consultation on the Shortening of the Settlement Cycle from T+2 to T+1, September 7, 2021
Letter to the State Securities Commission of Vietnam, regarding Key Custodian Banks' Concerns regarding the Proposed Vietnam CCP Model, October 12, 2020
Letter to the Honourable Nirmala Sitharaman, India Ministry of Finance, regarding Know Your Customer (KYC) Regulations: Non-alignment SEBI and RBI, September 14, 2020
Letter to the Honorable Yoon Suk-heun, Korea Financial Supervisory Service, regarding Investment Registration Certificate Applications and Documentation and Reconciliation by the FSS of IRC's Positions, February 26, 2020
Letter to The Securities and Exchange Board of India (SEBI) regarding Interoperability of Clearing Corporations, May 16, 2019
Letter to Ms. Pataravasee Suvarnsorn, Thailand Clearing House, regarding Thailand Clearing House - Pending Settlement, October 18, 2018
Letter to The Hon. Mr. Tariq Bajwa, State Bank of Pakistan, regarding Prudential Regulations for Corporate/Commercial Banking Regulation - M-1-Know Your Customer (Prudential Regulations), October 15, 2018
Letter to Mr. Achul Singh, Securities and Exchange Board of India, regarding KYC Requirements for FPI's, September 16, 2018
Letter to Honorable Mr. Ajay Tyagi, Securities and Exchange Board of India, regarding Securities and Exchange Board of India KYC Circular, 10/04/18, July 24, 2018
Letter to Ms. Pataravasee Suvarnsorn, Thailand Clearing House, regarding Thailand Clearing House - Pending Settlement, July 11, 2018
Letter to Honorable Mr. Eddie Yue Wai-man, Hong Kong Monetary Authority, July 17, 2017
Europe
EU T+1 Industry Committee Welcomes the Official Launch of the Governance Structure for the Transition to T+1 Settlement Cycle Press Release, January 22, 2025
Response to the ESMA Consultation Papers regarding Guidelines on Reverse Solicitation and Guidelines on the Conditions and Criteria for the Qualification of Crypto-Assets as Financial Instruments, April 29, 2024
Response to the ESMA “Consultation on Technical Advice on CSDR Penalty Mechanism”, February 29, 2024
Response to Second Consultation on the Technical Standards Specifying Certain Requirements of Markets in Crypto Assets Regulation (MiCA), December 14, 2023
AFME-AGC Joint Response to The Law Commission Public Consultation on Digital Assets, November 4, 2022
AFME-AGC Joint Response to UK Jurisdiction Taskforce Public Consultation for a Legal Statement on Digital Securities, October 31, 2022
Response to ESMA Call for Evidence on Shortening the Settlement Cycle, October 5, 2023
ESMA Call for Evidence: DLT Pilot Regime and Review of MiFIR Regulatory Technical Standards on Transparency and Reporting, March 4, 2022
European Commission Targeted Consultation on the Review of the Regulation on Improving Securities Settlement in the European Union and on Central Securities Depositories ("CSDR Review"); CSDR Review - AGC Response - Summary Extract, February 2, 2021
European Commission Public Consultation on the Review of the AIFMD - Investor Protection; Submission of the AGC European Focus Committee - Summary and Extract, January 29, 2021
Shareholder Rights Directive II Position Paper, August 4, 2020
Letter to the Financial Stability Board (FSB), regarding FSB's Discussion Paper on Regulatory and Supervisory Issues Relating to Outsourcing and Third-Party Relationships
Letter to the Assets & Residence Policy Team, HM Revenue and Customs, regarding the Fifth Money Laundering Directive and Trust Registration Service, Technical Consultation Document of January 24, 2020, February 21, 2020
Letter to the BEIS/Law Commission, regarding Intermediated Securities Call for Evidence, November 29, 2019
Letter to the HM Treasury, regarding Transportation of the Fifth Money Laundering Directive, June 10, 2019
Letter to Naerings og fiskeridepartementet, regarding Shareholders Rights Directive II (SRDII), March 29, 2019
Letter to European Commission, regarding Ares(2018)2778673 / Draft Delegated Regulation Amending Delegated Regulation (EU) No 2016/438 as Regards Safe-keeping Duties of Depositaries for UCITS Funds, and Ares (2018)2778659 / Draft Delegated Regulation Amending Delegated Regulation (EU) No 231/2013 as Regards Safe-keeping Duties of Depositaries for Alternative Investment Funds, June 26, 2018
EU Consultation on Conflict of Laws, June 30, 2017
Letter to Olga Petrenko, ESMA, regarding Clarification and Challenges for MiFID/MiFIR Transaction Reporting, June 29, 2017
Comment Communication Submitted on September 23, 2016 to ESMA, regarding Asset Segregation and Custody Services
Letter to European Securities and Markets Authority (ESMA), regarding AGC Response to ESMA's Consultation Paper on Guidelines on Participant Default Rules and Procedures Under CSDR, June 30, 2016
Consultation Paper on Regulatory Technical Standards on the CSD Regulation (“draft RTS”); The Operation of the Buy-In Process, 30 June 2015 (the “Consultation Paper”), August 6, 2015
European Securities and Markets Authority; European Banking Authority; European Insurance and Occupational Pensions Authority; Joint Committee of the European Supervisory Authorities -- regarding Draft Regulatory Technical Standards/Risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP under EMIR, July 10, 2015
European Commission Green Paper, Building a Capital Markets Union (the "Green Paper"), May 13, 2015
Middle East & Africa
Letter to the Central Bank of Nigeria, regarding Circulars Restricting Investments in OMO Bills: Impact on Foreign Global Custodians, December 20, 2019
Letter to the Securities and Exchange Commission of Zimbabwe, regarding Quilter Holdings: Concern regarding Irregular Registration and Safekeeping Arrangements, December 17, 2019
Letter to the Reserve Bank of Zimbabwe, regarding Request for Withdrawal of Documentation Requirements for Repatriation of Portfolio Disinvestments, June 26, 2019
Letter to the Reserve Bank of Zimbabwe, regarding Meeting with the Middle East & Africa, Association of Global Custodians and Standard Chartered Bank, February 12, 2019
Letter to Capital Markets and Securities Authority, regarding Insolvency Regimes, February 11, 2019
Letter to Qatar Central Securities Depository, regarding Removal of Custody Accounts in Qatar, January 24, 2019
Letter to The National Treasury (Kenya), regarding Taxpayer Identification Numbers, September 27, 2018
Letter to the Central Bank of Kenya, regarding, Central Bank of Kenya CDS Account Opening for Foreign Clients, September 24, 2018
Letter to The Commissioner Domestic Taxes, Zambia Revenue Authority, regarding Taxpayer Identification Numbers, August 16, 2018
Letter to The Chairman, Parliamentary Committee on Finance, Planning and Trade, regarding The Kenyan 2018/19 Tax Budget: Transfer Tax on Banks and Financial Institutions, July 11, 2018
Letter to Moremi Marwa (DSE) and Benitho Kyando (CSDR) regarding Tanzania CSDR Operational Guidelines for Custodians, June 22, 2018
Letter to Reserve Bank of Zimbabwe, regarding Repatriation of Foreign Investment Proceeds, May 24, 2018
Letter to The Central Bank of Bahrain, regarding Trade and Custody Accounts in Bahrain, May 2018
Letter to Capital Market Authority, regarding Middle East and Africa Committee, April 10, 2018
Letter to Central Bank of Bahrain, regarding Trade and Custody Accounts in Bahrain, April 10, 2018
Letter to Financial Regulatory Authority, regarding Beneficial Owner Documentation and Disclosure Requirements, December 20, 2017
Letter to the CMSA, responding to The Capital Markets Act 2016, December 17, 2017
Letter to Business and Intellectual Property Authority (BIPA) regarding Section 147 and 181 of the Companies Act (Act 28 of 2004), October 2, 2017
Letter to Dar Es Salaam Stock Exchange, regarding Suggested Amendments on the Directive to Improve Efficiency in Post Trade Process and Address Concerns of Global Investors, July 14, 2017
Letter to the CMSA, regarding Amendments to the Capital Markets Act 2016, June 21, 2017
Letter to Securities and Exchange Commission, Zimbabwe, responding to The Capital Markets Act, 2016; Subject to Supplemental Comments, April 30, 2017
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