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IMA Summary on Consultation on Amendments to Common Reporting Guidelines

Core Content

The Investment Management Association (IMA) has responded to a consultation paper issued by the Committee of European Banking Supervisors (CEBS) regarding amendments to the guidelines on common reporting. The IMA represents the UK asset management industry, which manages over £3.1 trillion of funds across the UK, Europe, and other regions. Their members include independent investment managers, retail banks, life insurers, investment banks, and occupational pension scheme managers.

The consultation paper addresses the lack of consistency in reporting obligations, particularly for cross-border groups. However, the IMA argues that the proposed amendments would impose more onerous reporting requirements on the majority of EU member states, leading to significant cost and resource implications for regulated institutions without providing additional regulatory benefits.

Main Views

• Timeliness vs. Quality: The IMA emphasizes that the key concern is not the speed of data reporting, but the ability of regulatory authorities to use appropriate information for effective supervision. They argue that reducing the time for report submission does not enhance regulatory benefits and may increase costs.

• Proportionality Principle: The IMA supports the introduction of the proportionality principle, as it aligns with the Capital Adequacy Directive. They believe that reporting requirements should be tailored to the risk profile of the institution, particularly for cross-border groups, and not apply uniformly across all institutions in Europe.

• Common Remittance Dates: The IMA agrees with the distinction between solo and consolidated reports. They highlight that consolidated reports involve data from multiple sources and jurisdictions, which justifies a longer submission period.

• Feasibility of Proposals: The IMA considers the proposals in the consultation paper to be more onerous than existing regimes in most EU member states. They question the regulatory benefit of faster reporting and argue that the costs outweigh any potential advantages.

• Transitional Arrangements: The IMA does not support the transitional arrangements proposed for EU-parent institutions, suggesting that the proposals should be amended rather than implemented with a transition period.

• Harmonisation of Reporting Frequency: The IMA agrees with the harmonisation of maximum reporting frequencies, provided that exceptions are appropriately considered.

Key Information

• Reporting Obligations: The current proposal would require many institutions to submit reports in a shorter timeframe than existing regulations, potentially increasing costs without proportional regulatory benefits.

• Cross-Border Groups: The IMA acknowledges that the lack of consistency in reporting obligations is a primary issue for cross-border groups, but argues that the solution should be proportionate and risk-based.

• Regulatory Benefits: The IMA believes that the existing regulatory regime in the UK already provides sufficient oversight, and that additional reporting requirements do not offer new benefits.

• Existing Framework: The IMA recommends using the recast Banking Consolidation Directive (2006/48/EC) to address cross-border reporting inconsistencies, as it already provides a framework for mitigating such issues.

Conclusion

The IMA does not support the majority of the proposed amendments to the common reporting guidelines. They argue that the proposals are inconsistent with the "better regulation" agenda and do not offer a proportionate or risk-based solution. Instead, they advocate for the use of existing regulatory frameworks to address cross-border reporting issues effectively and efficiently.