EBA欧洲银行-FBF_CP06_11页_1mb

FBF Response to CEBS Consultation Paper on Financial Reporting – CP06 Summary

Core Content

The Financial Business Federation (FBF) has provided detailed feedback on the CEBS Consultation Paper on Financial Reporting – CP06, which outlines a proposed supervisory financial reporting framework. The FBF expressed support for the goal of harmonizing financial reporting across Europe but criticized the consultation paper for being overly detailed and not fully aligned with IFRS disclosure requirements. They emphasized the need for a more rationalized and reduced version of the proposal.

Main Views and Concerns

The FBF identified several major issues with the proposed consultation paper:

• Excessive Detail: The 48 templates proposed are overly detailed, often going beyond IFRS disclosure standards and reducing the flexibility allowed by IFRS.
• Inconsistency with IFRS: Some requirements conflict with IFRS provisions, such as the mandatory separate reporting of accrued income and expenses from financial instruments, which IFRS allows to be offset.
• Lack of Harmonization: The consultation paper does not sufficiently address the need for harmonizing supervisory practices, leading to increased compliance and reporting burdens for banks operating in multiple countries.
• IT System Limitations: Many of the required data points are not available in the consolidated IT systems of banks, even if they are available in individual subsidiary systems.
• Discrepancies with French Standards: The FBF highlighted that the proposed format differs from the French accounting standard-setter's recommendations, which could lead to additional IT development costs and complexities.
• Unnecessary Granularity: The level of granularity required for certain disclosures, such as by "corporate" and "retail" categories, is not practical or supported by current systems.
• Redundancy and Overlap: Some tables and columns are redundant or inconsistent with other regulatory frameworks, such as the CoRep project, leading to duplication and confusion.

Key Recommendations

• Reduce the Number of Templates: The FBF recommends a significant reduction in the number and size of the templates to make the reporting framework more manageable.
• Align with IFRS Flexibility: They suggest that the consultation paper should respect the flexibility allowed by IFRS and not impose overly restrictive presentation formats.
• Clarify Definitions and Requirements: Ambiguities in the definitions and the lack of clarity on certain concepts (e.g., "own credit risk") should be addressed.
• Simplify Reporting Categories: For example, the FBF proposes combining "Additions from internal development" and "Additions from separate acquisition" into a single line.
• Avoid Overly Detailed Breakdowns: The FBF argues that many of the detailed breakdowns (e.g., by CRD portfolios, time bands, etc.) are not feasible or necessary and should be removed.
• Consider National Implementation Flexibility: The FBF stresses that the FinRep framework should allow for national flexibility to avoid imposing unnecessary costs on banks.

Conclusion

The FBF views the current consultation paper as only a preliminary step toward a harmonized financial reporting framework. They hope that CEBS will take their concerns into account and produce a more rationalized and practical second proposal. The detailed comments and suggestions are included in the attached appendix, which provides a comprehensive critique of each of the 48 templates.