EBA欧洲银行-Swe_CP06_14页_636kb

CEBS Consultation Paper on Financial Reporting Summary

Core Content

The Swedish Bankers' Association (SBA) has provided detailed feedback on the CEBS Consultation Paper (CEBS CP06) regarding the proposed Financial Reporting Framework. The SBA supports the idea of harmonising and standardising financial reporting across Europe, as it would enhance comparability, reduce reporting burdens for cross-border banks, and promote a level playing field in the European financial market. However, they highlight several issues with the current framework that hinder its effectiveness and consistency with international standards.

Main Views

• Harmonisation and Standardisation: SBA supports the goal of a harmonised reporting framework but believes the current proposal diverges from IAS/IFRS in several ways.
• Consistency with IAS/IFRS: The framework is not fully aligned with IAS/IFRS, particularly in the use of Common Practice (CP) and in the level of detail required.
• Reporting Scope and Frequency: SBA considers the framework too detailed and proposes that certain items should be reported less frequently, such as detailed tables and notes, to avoid unnecessary burdens on banks.
• Implementation Timing: They suggest that the implementation of the Financial Reporting Framework should be delayed until 2008, to allow sufficient preparation time and avoid interfering with the implementation of the Common Reporting Framework for Solvency Reporting.
• XBRL Taxonomy: SBA agrees that XBRL is a suitable tool for standardised reporting but recommends using the IFRS taxonomy without introducing alternatives.

Key Concerns

• The framework includes Common Practice (CP) items, which are not universally applied across the EU and create inconsistencies.
• The framework exceeds IFRS disclosure requirements, particularly in the income statement and cash flow statement templates.
• Some reporting items are not IFRS consistent, such as the categorisation of financial instruments and the use of terms like "Micro hedge".
• Data availability is a concern, as the framework requires information that may not be readily available in banks' IT systems.
• The choice of reporting frequency is not aligned with the practical needs of supervisors and banks, with SBA suggesting that some items should be reported annually or on demand rather than quarterly.

Specific Comments on the Framework

• The framework should be restricted to IFRS-consistent items and remove CP references.
• The reporting frequency should be differentiated, with consolidated balance sheets and income statements reported quarterly, while detailed tables and notes should be reported annually or on demand.
• The use of XBRL should be based on the IFRS taxonomy, not alternatives.
• The portfolio approach is not in line with IFRS and should be replaced with a product-based approach.
• Definitions and classifications should be harmonised with the Solvency Reporting Framework.

Comments on Specific Tables

Table 1.1 Consolidated Balance Sheet - Assets

• Should be reported quarterly.
• Terms like "loans and receivables" and "loans and advances" should be made uniform.
• Sector codes are not an IFRS requirement and should be removed.
• The categorisation of financial assets should follow IAS 39 categories.

Table 1.2 Consolidated Balance Sheet - Liabilities

• Should be reported quarterly.
• Provisions should be clarified and aligned with IAS 37.
• Liabilities related to financial leases should be included in the relevant category.

Table 1.3 Consolidated Balance Sheet - Equity and Minority Interest

• Should be reported quarterly.
• Detailed specifications in notes should be reserved for annual or ad hoc reporting.

Table 2. Consolidated Income Statement

• Should be reported quarterly.
• References to IAS/IFRS should be included for clarity.
• Gains and losses should be reported net where possible.
• Provisions should be clearly defined and aligned with IAS 37.

Tables 3–9

• These tables are considered to go beyond IFRS requirements and should be either removed or simplified.
• Counterparty breakdowns are not appropriate and should be eliminated.
• The use of terms like "Micro hedge" and "Derivatives used for hedging" is not IFRS consistent and should be revised or removed.

Conclusion

The Swedish Bankers' Association advocates for a more IFRS-aligned, less detailed, and more practical financial reporting framework. They recommend that CEBS should focus on core financial statements and remove CP items, while also aligning definitions and classifications with existing international standards and supervisory frameworks. A clearer purpose for the reporting items and appropriate reporting frequency are essential to ensure that the framework is both effective and manageable for banks and supervisory authorities.