EBA欧洲银行-CP06revised2_FRSGlobal_4页_166kb

FRSGlobal Comments on FINREP Amendments Consultation Paper (10 March 2009)

Introduction

FRSGlobal welcomes the proposed amendments to the Guidelines on Financial Reporting (FINREP), particularly the efforts to streamline and harmonize report templates. These changes aim to improve transparency and consistency across financial reports, making cross-border data more valuable. The organization supports the initiative to provide clear definitions for all items and believes that the removal of unnecessary detail will help in focusing on the essential aspects of financial reporting.

The Maximum Data Model

FRSGlobal acknowledges the significance of the 'maximum data model' but raises concerns about its practical impact. Currently, national supervisors use National Discretions to include additional information in their reports. If this flexibility is removed, the organization questions how to encourage the use of Non Core reports and prevent national supervisors from defining their own report sets, which could lead to misalignment. FRSGlobal suggests that local variations do not hinder alignment and that the current system allows for quick adaptation. Clear guidelines are expected to resolve differences in form completion, but the organization is concerned that without them, national supervisors might revert to their own definitions.

XBRL Adoption

FRSGlobal notes that XBRL adoption varies significantly across countries. While it believes XBRL can aid in harmonization, the lack of direct incentives for adoption is a concern. The organization asks whether CEBS has a program in place to promote XBRL use, as it is essential for consistent reporting across jurisdictions.

Convergence with Other Bodies

FRSGlobal supports the efforts to align FINREP with standards from the ECB, BIS, IMF, and other regulatory bodies. However, it raises questions about the reconciliation of financial information across different regulators and the need for further analysis to address gaps. The organization also inquires about the impact assessment of changes to other regulations, such as ECB 25/2009, and whether such changes have been considered in the harmonization process.

Convergence with CRD/Basel II

The organization highlights that while the current templates do not show significant gaps between IFRS and CRD/Basel II, there are inconsistencies. For instance, the classification of securitized debt as either a liability or equity leads to discrepancies in reporting. Additionally, netted balances in FINREP may require adjustments in notes under the new templates. FRSGlobal is unsure about the definitive requirements for the column 'Amounts derecognized for capital purposes' on Template 11, Table A, as it depends on local regulations.

Frequency of Production

FRSGlobal suggests that aligning the frequency of production for Core and Non Core reports could help avoid data sourcing issues. For example, if Core reports are submitted quarterly and Non Core reports annually or semi-annually, inconsistencies may arise due to different data sources and line allocations. The organization recommends that this be considered as a 'best practice' in the guidelines, especially for reports where detailed data is not frequently available.

Timeline

FRSGlobal finds the proposed end date of 1st January 2012 for adoption overly long. Although delays in standard finalization, such as IAS 39, are acknowledged, they argue that these changes will not introduce major data requirements. The organization believes that its systems and solutions are capable of adapting quickly to new regulations and that the timeline could be significantly shortened.

Conclusion

Overall, FRSGlobal supports the proposed amendments to FINREP and looks forward to participating in the implementation discussions. It emphasizes its cross-regional expertise and willingness to assist in improving financial reporting standards. The organization also highlights its role as a provider of risk and regulatory solutions, offering enterprise-wide risk profitability analysis and global regulatory reporting to over 1500 financial organizations, including 41 of the top 50 banking institutions.