EBA欧洲银行-IBF_CP06_4页_198kb

Summary of the Irish Bankers Federation's Response to CEBS Consultation Paper on Financial Reporting

1. Introduction

The Irish Bankers Federation (IBF) supports the Committee of European Banking Supervisors' (CEBS) objective of developing a harmonised consolidated financial reporting framework aligned with International Financial Reporting Standards (IFRS). They believe that such a framework would enhance the comparability of financial data across the European financial services market and promote a level playing field. However, the IBF acknowledges that the proposed framework represents a significant shift from current reporting practices in Ireland and poses a substantial challenge for its members.

2. General Concerns

2.1 Scope of the Framework

• The proposed framework includes reporting items that go beyond the IFRS disclosure requirements.
• The IBF believes the scope is excessive and that the framework should be limited to information required for IFRS compliance.
• References to IAS 39, which only provides definitions and not disclosure requirements, are problematic.

2.2 Flexibility vs. Standardisation

• The IBF is concerned that allowing national authorities to add additional reporting requirements undermines the goal of standardisation.
• They argue that this provision could lead to diverging national reporting practices and reduce the effectiveness of the harmonised framework.
• The only acceptable scenario for such flexibility would be if the framework were limited to the Income Statement and Balance Sheet format.

2.3 Lack of Coordination

• The IBF regrets the lack of coordination between this project and the common prudential reporting project.
• They believe that IFRS has been in effect since 1 January 2005 and that the two projects should be aligned to create a comprehensive reporting package.
• A second consultation or final proposal should integrate the outcomes of both projects to ensure coherence.

3. Specific Comments

3.1 IAS/IFRS Consistency

• The IBF disagrees with the inclusion of items that are not part of IFRS disclosure requirements, such as the reporting of derivatives held for trading.
• Some templates request data that is not consistent with IFRS, like the breakdown of gains and losses on a gross basis instead of a net basis as required by ED 7.21.
• The framework also incorporates CEBS-specific product categorisations and prudential exposure classifications that are not aligned with IFRS.

3.2 Common Practice (CP)

• The IBF opposes the inclusion of any item labeled as "Common Practice".
• They argue that some items are not common practice among their members, such as the separate monitoring of exchange difference revaluations.
• They believe that the term "Common Practice" is not yet applicable due to the recent implementation of IFRS across Europe.

3.3 Availability of Data

• Some data requested by the framework is not readily available in the IT systems of member banks.
• Examples include detailed information on repos and reverse repos, as well as the breakdown of profit and loss items by specific financial instruments or product categories.
• These breakdowns require manual input and are not easily accessible, leading to increased administrative burden.

4. Additional Steps for Convergence

• The IBF suggests that CEBS should restrict the framework to data already compiled for IFRS compliance.
• They recommend using the income statement and balance sheet format as the starting point for harmonisation.
• A phased approach should be adopted, with CEBS reviewing the framework after an initial implementation period to gradually introduce additional templates.
• The guidance should be based solely on IFRS disclosure requirements, avoiding restrictions on accounting options.

5. Guidance Appropriateness

• The IBF welcomes the explanatory guidance provided by CEBS, as it promotes a common understanding across the EU.
• However, they are concerned about the guidance that restricts accounting options, such as the mandatory reporting of accrued interest as a separate item in the balance sheet.
• They believe that CEBS should not influence the application of accounting standards through its guidance.