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EAPB Comments on CEBS' Consultation Paper on Amendments to the Guidelines on Common Reporting (COREP)

Core Content

The European Association of Public Banks (EAPB) has provided detailed feedback on the CEBS consultation paper regarding proposed amendments to the COREP Guidelines. The EAPB represents 28 public banks, funding agencies, and associations across Europe, collectively representing approximately 100 public financial institutions with a total balance sheet of about EUR 3,500 billion and employing around 190,000 people.

Main Views and Key Points

1. Feasibility of FINREP Approach

• The EAPB does not provide a direct response to whether the future proposal on FINREP should follow the same approach as COREP.

2. Balance Between Timeliness and Data Quality

• The EAPB generally agrees with CEBS' attempt to improve convergence in remittance dates and reporting frequencies.
• They support the idea of a minimum remittance date but do not share CEBS' concerns about its impact on cross-border groups.
• They argue that the proposed 15 business days remittance period for solo reports is insufficient for collecting high-quality data.
• They suggest extending the remittance period for solo reports to at least 20 business days to ensure data quality without compromising timeliness.
• They consider a remittance period of at least 35 business days for consolidated reports to be acceptable.

3. Application of the Proportionality Principle

• The EAPB believes that the proportionality principle is not necessary for the proposal.
• They advocate for a general quarterly reporting frequency, regardless of the institution's size.

4. Distinction Between Solo and Consolidated Reports

• The EAPB agrees with CEBS' decision to apply common remittance dates but differentiate between solo and consolidated reports.

5. Feasibility of the Proposal

• Solo Reports: The EAPB does not believe that reporting on a solo basis within 15 business days is feasible. They argue that this would lead to inappropriate additional costs and that even with extra resources, the time required to prepare the reports cannot be significantly reduced.
• Consolidated Reports: They believe that a remittance date of at least 35 business days is feasible.

6. Transitional Arrangement for EU-Parent Institutions

• The EAPB agrees with the proposed transitional arrangement for EU-parent institutions.

7. Harmonisation of Maximum Reporting Frequency

• The EAPB welcomes the proposal to set quarterly reporting as the maximum frequency for both solo and consolidated reports.
• However, they disagree with the exception allowing national authorities to require monthly reporting for the CA template on a solo basis if the data was collected by December 31, 2007.
• They suggest removing this exception, as most Member States already request quarterly reporting.

Additional Suggestions

• The EAPB recommends conducting a more in-depth analysis of reporting frequencies, split by country and type of report, to better understand the implications of the proposed changes.

Conclusion

The EAPB emphasizes the importance of maintaining data quality while aiming for harmonization in reporting practices. They advocate for a more realistic remittance period for solo reports and the removal of the exception for the CA template, while supporting the overall goal of standardizing reporting frequencies across the European banking sector.