EBA欧洲银行-Presentation-Disclosure-guidelines-Hearing-226-Jan-2010_28页_330kb

Summary of the Public Hearing on the Draft CEBS Disclosure Guidelines: Lessons Learnt from the Financial Crisis (CP30)

Background

The CEBS (Committee of European Banking Supervisors) issued CP30, a set of 16 high-level principles aimed at improving risk disclosures in stressed situations. These principles are not intended to amend, duplicate, or add to existing disclosure requirements but rather to enhance the form and content of disclosures regardless of the regulatory context (e.g., IFRS, Pillar 3, listing rules). The guidelines were published in October 2009 and underwent a 3-month consultation period, ending on 15 January 2010, during which 11 responses were received.

Main Comments and Concerns

General Comments

• Support: Most respondents supported the initiative, appreciating the use of high-level principles and the non-compulsory nature of the guidelines.
• Concerns:
  • Risk of information overload due to the detailed nature of the guidelines.
  • Need for clarification on how the guidelines interact with existing disclosure requirements.
  • Ambiguity in defining "stressed circumstances".
  • Suggestions for global coordination of disclosure initiatives.
  • Questions about enforcement of the principles.

Stressed Circumstances

• There was a call for clarity on what constitutes a "stress" situation, as the current definition is too broad.
• CEBS initially did not define "stress" but has since acknowledged the need for further consideration.

Comments on Section I: General Principles

Principle 1: Timely and up-to-date information

• Some respondents viewed it as a new requirement that could increase costs and publication frequency.
• CEBS supports the principle and suggests that the publication calendar should ensure timeliness.

Principle 2: Adequate information on areas of uncertainty

• Concerns were raised about overly detailed sensitivity analyses and their practical implementation.
• Suggestions include differentiating between reported data and forward-looking statements.
• CEBS emphasizes the need for balance between comprehensiveness and clarity.

Principle 3: Comprehensive and meaningful information

• Concerns about coordination with competent authorities and management discretion.
• CEBS notes that omissions should also be addressed, though not specified.

Principle 4: Comparability of disclosures

• Some respondents worried about increased disclosure formats and information overload.
• CEBS believes that comparative information is useful and not an increase in required information.

Principle 5: Early adoption of new standards

• Support was given for early adoption, but concerns were raised about quality and IT system upgrades.
• CEBS encourages early adoption without compromising quality.

Principle 6: Verification by external auditors

• Some respondents requested guidance on how to apply this principle.
• CEBS views it as good practice but does not require verification.

Comments on Section II: Content

Principle 7: Business model under stress

• Concerns about the form and detail of business model disclosures.
• CEBS has no strong views on the format, but emphasizes sufficient detail for external users.

Principle 8: Impacts on results and risk exposures

• Concerns about forward-looking information and its subjectivity and legal implications.
• CEBS supports the principle but recognizes the need for caution and caveats.

Principle 9: Impacts on financial position

• IFRS 7 is considered sufficient for liquidity risk.
• No new specific comments were raised beyond general concerns about forward-looking information.

Principle 10: Risk management of stressed activities

• A concern was raised about self-fulfilling prophecies.
• CEBS clarifies that the principle is about describing actual measures, not imposing artificial corrective actions.

Principle 11: Sensitive accounting issues

• Some respondents warned against extensive scenario disclosures that might undermine financial reporting quality.
• CEBS acknowledges the sensitivity of these issues but stresses that quality does not depend on quantity.

Comments on Section III: Presentational Issues

Principle 12: Centralized disclosure

• Some respondents believe centralization is up to the institution.
• CEBS encourages centralizing information related to the same stress circumstances, without regrouping disclosures from different regulations.

Principle 13: Granularity of transparency

• Concerns about information overload and granularity vs. time frame.
• CEBS supports the management discretion to balance timeliness and detail.

Principle 14: Balance between quantitative and narrative information

• No significant concerns were raised, and support was generally given.

Principle 15: Educational approach

• Some respondents argued that education is not the primary goal of financial statements.
• Others welcomed the idea of executive summaries and narrative storytelling.
• CEBS emphasizes consistency and a balance between educational content and clear disclosures.

Principle 16: Non-involvement in stressed activities

• Concerns about legal liability and potential misinterpretation.
• CEBS supports the principle but stresses the need for management judgment in specifying non-involvement.

Questions and Next Steps

Questions Raised

• Are there other comments on the draft guidelines?
• How should CEBS proceed with the guidelines?
• What would be the costs and benefits?
• Any other considerations?

Next Steps

• CEBS will prepare a feedback document within 3 months after the consultation period.
• Impact assessment will be conducted.
• A follow-up proposal will be submitted to CEBS for further review.