The Office of the Superintendent of Financial Institutions (OSFI) is consulting on proposed amendments to its Pillar 3 Disclosure Guideline related to Interest Rate Risk in the Banking Book (IRRBB). The proposed changes would introduce new public disclosure requirements for Domestic Systemically Important Banks (D-SIBs) and Category 1 Small and Medium-Sized Deposit-Taking Institutions (SMSBs), including federal credit unions, that fall within this category.  

Although the proposed amendments would apply only to D-SIBs and Category 1 SMSBs, OSFI guidance often influences supervisory expectations and regulatory approaches adopted by provincial regulators. As a result, the proposed framework may have implications for the broader credit union sector.  

The proposed disclosures are intended to improve transparency around institutions’ exposure to interest rate risk, strengthen market discipline, enhance comparability across institutions, and align Canadian disclosure requirements with recent revisions to the Basel Committee’s IRRBB framework. OSFI’s consultation closes on July 20, 2026. Final guidance is expected on September 10, 2026, with the new disclosure requirements proposed to take effect for fiscal reporting periods ending in Q4 2027.  

CCUA has developed a draft response to OSFI’s consultation questions. Credit unions interested in reviewing the outline of the proposed submission can click here to download the document.

Members interested in providing feedback are encouraged to contact Rhys McKendry.