Deutsche Börse Group Position Paper on EBA Consultation Paper reporting requirements for institutions (CP 50)” issued on 20 December. EBA consultation paper on draft ITS on supervisory reporting requirements supervisory reporting requirements for institutions (CP50). The BSA frequently comments on consultative papers issued by the Financial Conduct Authority and Prudential Regulation Authority, and by.

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Responding to this Consultation Draft Implementing Technical Standards on Supervisory reporting requirements for institutions Draft Impact Assessment c. Overview of questions for Consultation. Comments are most helpful if they: Please note that comments submitted after the deadline, or sent to another address will not be processed.

Publication of responses All contributions received will be published following the close of the consultation, unless you request otherwise. Please indicate clearly and prominently in your submission any part you do not wish to be publically disclosed. A standard confidentiality statement in an message will not be treated as a request for non-disclosure.

A confidential response may be requested from us in accordance with the EBA s rules on public access to documents. We may consult you if we receive such a request. Data protection Information on data protection can be found at under the heading Copyright and Disclaimer. These ITS will be part of the single rulebook enhancing regulatory harmonisation in Europe with the particular aim of specifying uniform formats, frequencies and dates of prudential reporting as well as IT solutions to be applied by credit institutions and investment firms in Europe.

This consultation paper puts forward a draft ITS related to Articles 95 own funds and financial information and 96 losses stemming from lending collateralised by immovable property of the CRR. To the extent that the text potentially changes as a result of ongoing negotiations among EU institutions, EBA will adapt its draft ITS accordingly to reflect any developments.

However, in relation to financial information, the consultation is currently limited to the requirements to be submitted by credit institutions on a consolidated basis only.

The background and rationale for this exception are further explained in section III below. Uniform reporting requirements are necessary to ensure fair conditions of competition between comparable groups of credit institutions and investment firms and will lead to more efficiency for institutions and more convergence of supervisory practices.

Given that there is not as yet harmonisation on the underlying accounting frameworks applied in the various Member States, the ITS has taken this into account when defining the formats and wba of supervisory reporting. The ITS does not intend to harmonise the underlying valuation measures. As the ITS will apply to all institutions subject to supervision under CRR, subject to the above mentioned restriction for financial information, reporting requirements have been developed taking into account the nature, scale and complexity of institutions’ activities.

Proportionality is co50 integral part of the ITS with certain reporting requirements being applicable only to institutions using complex approaches to measure own funds requirements or to institutions that have significant risk c;50. Therefore, the first regular reporting period thereafter is expected to cp05 Q with the first reporting reference date being In order to provide for a sufficiently long implementation period the EBA intends to finalise the draft ITS and submit it to the Commission by months ahead of the first reporting reference date.

The proposed submission date assumes ccp50 a final CRR will be available beforehand. Institutions will have to submit a first set of data related to the reference date of to national authorities by 13 May It is important to keep in mind that ebq of the CRR might change which will impact the above dates related to the ITS timeline. These are currently being debated by the EU legislators Council and European Parliament in the framework of the co-decision procedure.

This approach, to draft the ITS on supervisory reporting on the basis of what is expected to be the text of the CRR, was deemed a more efficient way forward, as it will allow eb reporting requirements to be based on the new own funds requirements contained eva the CRR proposalssubject to the specific provisions regarding financial information, set down below.

This is a preferred option as it avoids the additional implementation costs that would arise if uniform reporting requirements were in place before the application of CRR. According to Article 15 4 of EBA regulation, they shall be adopted by means of regulations or decisions.


This means that, on the date of their entry into force, they become part of the national law of the Member States and that their ebba into national law is not only unnecessary but also prohibited by EU law, except in so far as this is expressly required by them. Shaping these rules in the form of a Regulation would ensure a level-playing field by preventing diverging national requirements and would ease the cross-border provision of services since each time an institution wishes to take up operations in another Member State it currently has to assess a different set of rules.


Background and regulatory approach followed in the draft ITS Originally there were different supervisory reporting frameworks in the various Member States. As this led to inefficient outcomes and increased costs for cross-border firms, national supervisory authorities, in the context of their co-operation within CEBS, the predecessor of EBA developed guidelines regarding supervisory reporting requirements. In the context of the single European rulebook the harmonisation of supervisory reporting requirements is taking the next step and the CRR proposal requests EBA to develop ITS on supervisory reporting to cover both prudential and financial information, the latter to the extent necessary to obtain a comprehensive view of the risk profile of an institution s activities.

As the ITS will apply c;50 all institutions subject to supervision under CRR, subject to the specific provisions regarding financial information, set down below, reporting requirements have been developed taking into account the nature, scale and complexity of institutions’ cp550.

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Proportionality is an integral part of the ITS with certain reporting requirements being triggered by the use of complex approaches to measure institutions risk, the business model of institutions or a risk based assessment of institutions activities done by competent authorities. Also, specific reporting requirements of the ITS are triggered by quantitative thresholds with the objective to reduce administrative burden for institutions with insignificant activities while still capturing significant exposures.

However, the requirements regarding financial information as put forward in this consultation paper are limited sba credit institutions and only apply only on a consolidated basis. These requirements apply to credit institutions disregarding the accounting framework i. The development of requirements regarding financial information on an individual basis will need more time in order to overcome challenges stemming from the application wba different underlying accounting standards and issues linked to the reconciliation with statistical, monetary and fiscal reporting requirements.

The EBA will c;50 working on developing these uniform requirements taking into account the final provisions of Article 95 of CRR as approved by the Council and the European Parliament. If the final CRR provisions confirm that the scope and level of c;50 defined in the CRR needs to be followed by the ITS also in relation to financial information i. The information content of that second potential consultation is expected to be cp0 to a large extent on the templates proposed in this consultation package and to be applied in a proportionate manner i.

Depending on the timing of its finalisation, the application date regarding financial information on an individual level may be later than for the requirements rba down in this ITS. Where this is the case, this explanatory text appears in a framed text box. Thus, reporting regimes differ in many ways. The increased cross-border activity within the Union undertaken by the large financial intermediaries and the growing integration in financial markets uncovered the need for common reporting schemes across jurisdictions, both to reduce the burden on institutions and to ena a more effective supervisory framework with comparable prudential information.

A standardised reporting system facilitates efficient monitoring of compliance with regulatory requirements, helps to evaluate the risks to which these institutions are or might be exposed and serves to monitor developments within eb financial services sector.

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The harmonization of reporting requirements also aims to improve the efficiency of banking supervision by providing comparable information and contributing to the efficiency of reporting procedures within institutions. To reduce reporting burden and dp50 that the requirements of this regulation are fully met, it may be appropriate for competent authorities to incorporate the unified data requirements into a broader national eva framework established under their responsibility and which serves other supervisory purposes.

Hence, the provisions in this regulation do not restrict competent authorities to request institutions under their supervision to submit additional reports for purposes other than the one of this regulation e. Fp50 requirements for credit institutions and investment firms are necessary to ensure similar safeguards for savers and fair conditions of competition between comparable groups of credit institutions and investment firms.

The EBA should set a reporting policy applicable to supervised institutions aimed both at having a minimum reporting data set used to perform its tasks and duties and reducing the reporting burden on the banking sector. This Regulation lays down uniform requirements that all institutions subject to the Regulation of the European Parliament and of the Council on prudential requirements for cp5 institutions and investment pc50 hereinafter CRR must meet relating to the submission of supervisory data to competent authorities for the following areas: Explanatory text for consultation purposes The templates and instructions for point c on large exposures are not finalised yet and will be subject to a separate consultation which will be launched in the first quarter of Article 2 Definitions 1.

For financial information the reporting in this proposal includes only reporting on a consolidated level. CRR scope of consolidation is required to verify calculation of own funds requirements and enhance analytical abilities in the combined use of own funds figures and financial figures.


For financial information the scope of consolidation shall therefore also follow the CRR scope The scope of consolidation used for annual accounts and publication may differ for some institutions, because insurance companies and non-financial corporations are excluded from the CRR scope of consolidation.

How would you assess the cost impact of using only the CRR scope of consolidation for supervisory reporting of financial information?

Please specify cost implications if parts 1 and 2 of Annex III and of Annex IV of this regulation would be required, in addition to the CRR scope of consolidation, with the accounting scope of consolidation. In addition, the following definition of domestic exposure shall apply. The reporting co50 dates shall be: Article 3 Quarterly reporting: Information reported shall be as at the reference date set out in paragraph 1.

Information submitted pursuant to the templates set out in Annex III and Annex IV and according to the instructions in Annex V of this regulation referring to a period shall be reported cumulatively from the first day of the accounting year to the reference date.

Explanatory text for consultation purposes The proposal enables institutions to use the applicable accounting year for supervisory reporting purposes. Financial information will also be used on a cross-border level and aggregated at European level, requiring adjustments to enable comparability.

How cpp50 you assess the impact if cpp50 last sentence of Article 3 2 referred to the calendar year instead of the accounting year? Reports shall be submitted by institutions to competent authorities by close of business on the following remittance dates at the latest: If the remittance day is a public holiday, Saturday or Sunday, reporting requirements shall be transmitted on the following working day.

The above remittance dates concern the submission of unaudited figures which are figures that have not been assessed by external auditors. Where applicable, audited figures implying changes in already reported data shall be submitted as soon as available. In addition, any errors in the submitted reports shall be corrected by the reporting institution by submitting the necessary revisions to the relevant competent authority as soon as possible.

Explanatory ebw for consultation purposes The proposed uniform remittance period is 30 business days for both reporting on an individual and a consolidated level. Does having the same remittance period for reporting on an individual and a consolidated level allow for a more streamlined reporting process?

How would you assess the impact if remittance dates were different on an individual level from those on a consolidated level? When would be the earliest point in time to submit audited figures? Do you see any conflicts regarding remittance deadlines between prudential and other reporting e. CHAPTER 3 Format and frequency of reporting on own funds requirements and financial information Section 1 Format and frequency of reporting on own funds requirements Article 5 Format and frequency of reporting on own funds on an individual basis 1.

Reporting of the following information shall be done with a quarterly frequency: Information on the geographical distribution of exposures shall be submitted for each country with total exposures of equal or higher than 0.

This calculation shall be done for each exposure class individually. Conversely, an institution shall report the breakdown for all exposure classes if this materiality threshold is met, with reference to countries for which the 0.

The same conditions apply to the financial reporting threshold. Do the proposed criteria lead to a reduced reporting burden? What proportion of your total foreign exposures would be covered when applying the proposed thresholds?

Please also specify the number of countries that would be covered with the proposed threshold, both in aggregate and separately for each exposure class. What would be the cost implications if the second threshold of Article 5 point 1 c ii were deleted? Is the calculation of the threshold sufficiently clear?

Subject to prior decision by the competent authority, reporting of the information to be submitted pursuant to Paragraph 1 may be done with a semi-annual frequency where all of the criteria referred to in points a to c are met. As regards the decision, the competent authority shall take into account the criteria set out in Article 5 3. Balance sheet total figures shall be based on yearend figures for the year before the year preceding the reporting reference date.

Explanatory text for consultation purposes Do reduced reporting frequencies lead to significant reductions in administrative burden? Please quantity the estimated impact of semi-annual reporting frequencies compared to quarterly.

Competent Authorities are obliged to disclose data on the national banking sector s total assets as part of the supervisory disclosure. Do you find these publications sufficient to calculate the proposed threshold? However, EBA is cognisant of potential cost implications and is very interested in specific feedback on this point.