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FBF Response to CEBS Consultation Paper on Supervisory Disclosure (CEBS CP05) Summary

Core Content

The French Banking Federation (FBF) has responded to the CEBS consultation paper on the framework for Supervisory Disclosure, expressing overall support for the initiative. The FBF believes that the proposed framework aligns with the goals of increasing transparency and promoting convergence in supervisory practices across Europe, which would benefit both the banking industry and regulatory authorities. The FBF also emphasizes the importance of cost efficiency and appropriate prudential reporting in the context of this framework.

Main Views

The FBF supports the CEBS approach of making supervisory data accessible online, but highlights the need for more user-friendly formats, such as Excel, instead of PDF, to facilitate data extraction and analysis. They also suggest that the CEBS framework should be updated in line with the ongoing European reporting project (COREP) to ensure compatibility and ease of use.

The FBF advocates for the real-time updating of data, with clear responsibilities assigned to ensure accuracy and reliability. They propose that the CEBS should take charge of data control and provide users with alerts about any updates. Including a date column to indicate the last update time is also emphasized as a critical feature.

Additionally, the FBF suggests that the framework should initially be extended to the USA and Asia to cover "Rules and Guidance" in order to promote a broader level of transparency and convergence. They believe that disclosing the options and national discretions exercised by institutions is essential for transparency and could help reduce the number of such options over time.

The FBF acknowledges that supervisory disclosure is a novel concept and recommends that the CEBS revise the framework after one or two years to address unforeseen challenges and improve its effectiveness.

Key Information

• Support for CEBS Objectives: The FBF supports the CEBS aims of credibility, transparency, and promoting a level playing field in Europe.
• Data Accessibility: They support the online availability of data but suggest using more compatible formats like Excel.
• Alignment with COREP: The FBF recommends updating the CEBS framework to align with the European reporting project (COREP).
• Real-Time Data Updates: They emphasize the need for real-time updates and clear responsibilities for data management.
• Alert System: The inclusion of an alert system for data updates is seen as crucial to avoid misleading users.
• Extension to Other Regions: The FBF suggests extending the framework to the USA and Asia for "Rules and Guidance" at the beginning.
• Transparency of Discretions: They advocate for the disclosure of national discretions and options used by institutions to enhance transparency.
• Framework Review: They propose a review of the framework after one or two years to refine and improve it based on practical experience.

Conclusion

The FBF sees the CEBS consultation on Supervisory Disclosure as a significant opportunity to enhance transparency and convergence in European banking supervision. They offer constructive feedback on the proposed framework, focusing on data accessibility, real-time updates, and the need for alignment with existing reporting standards. Their suggestions aim to make the framework more practical, user-friendly, and effective for both the industry and supervisors.