UK Finance  has responded to the Basel Committee's consultation on updating the Pillar 3 disclosure framework. Whilst fully supporting the principle of comprehensive disclosure of key  metrics to support increased understanding by investors of a bank's risk profile we were concerned that some aspects of the proposals were too granular and are not aligned with European  proposals which have been recently finalised. In particular we suggested that confidential or proprietary information could be revealed in relation to Credit Valuation Adjustment and that the benchmarking of Internal Ratings Based credit risk outputs to the standardised approach may unhelpfully focus users on the standardised approach, at the expense of IRB approaches, which in our view are a better assessment of the risks a bank faces.