EBA欧洲银行-CP50-ITS-on-reporting_35页_482kb

EBA Consultation Paper Summary: Draft Implementing Technical Standards on Supervisory Reporting Requirements for Institutions (CP 50)

Core Content

This consultation paper outlines the Draft Implementing Technical Standards (ITS) on supervisory reporting requirements for credit institutions and investment firms, as mandated by the Capital Requirements Regulation (CRR). The EBA aims to develop a single rulebook across the EU to ensure regulatory harmonisation and convergence in supervisory practices. The ITS focuses on three main areas:

1. Own funds requirements and financial information (Article 95 of the CRR)
2. Losses stemming from lending collateralised by immovable property (Article 96 of the CRR)
3. Large exposures (Article 383 of the CRR)

The paper invites feedback on the proposed standards, particularly on the specific questions outlined in Section V/c, and encourages stakeholders to provide clear rationale, evidence, and alternative regulatory choices.

Main Features of the Draft ITS

• Scope and Application: The ITS applies to all credit institutions and investment firms under the CRR, with a limited scope for financial information reporting, which is restricted to consolidated reporting.
• Uniformity and Convergence: The goal is to ensure uniform formats, frequencies, and dates for supervisory reporting to enhance competition fairness and supervisory efficiency.
• Proportionality: The ITS incorporates proportional reporting requirements to avoid unnecessary burden on smaller or less complex institutions. Certain requirements apply only to institutions with complex risk measurement approaches or significant risk exposures.
• Use of COREP and FINREP: The ITS is based on existing COREP and FINREP guidelines, which have already been implemented in several EU Member States and have contributed to reporting convergence.
• IT Solutions: The ITS includes IT solutions for data submission, aiming to streamline the process and ensure compliance with the new reporting standards.

Key Requirements and Reporting Timelines

• Reporting Reference Dates: Quarterly reports are due on 31 March, 30 June, 30 September, and 31 December. Semi-annual reports are due on 30 June and 31 December, and annual reports on 31 December.
• Remittance Dates: Reports must be submitted by close of business on the following dates:
  • Quarterly: 12 May, 11 August, 11 November, and 11 February
  • Semi-annual: 11 August and 11 February
  • Annual: 11 February
• Submission of Audited Figures: If applicable, audited figures must be submitted as soon as they become available. Unaudited figures are required for unaudited reporting.
• Geographical Reporting Thresholds:
  • Institutions must report the geographical distribution of exposures if non-domestic exposures are 10% or more of total exposures.
  • Reporting is also required for countries with total exposures of 0.5% or more of total exposures.
• First Reporting Reference Date: 31 March 2013
• First Submission Deadline: 13 May 2013
• Finalisation Deadline: The EBA aims to finalise the draft ITS and submit it to the European Commission by 30 June 2012 (9 months before the first reporting date).

Key Considerations and Questions for Consultation

• Scope of Consolidation: The EBA uses the CRR scope of consolidation for financial information, which may differ from the accounting scope of consolidation for some institutions.
  • Question 1: How would you assess the cost impact of using only the CRR scope of consolidation for financial information reporting?
  • Question 2: What are the cost implications if the accounting scope of consolidation is also required alongside the CRR scope?
• Proportionality and Thresholds: The 10% and 0.5% thresholds are used to determine when geographical breakdowns are required. The EBA seeks feedback on:
  • Whether these thresholds reduce reporting burden.
  • The proportion of foreign exposures and the number of countries affected by the thresholds.
  • The cost implications of removing the 10% threshold.
  • Whether the threshold calculation is clear and well-defined.
• Reporting Frequency: The EBA proposes a uniform remittance period of 30 business days for both individual and consolidated reporting.
  • Question 3: Does a uniform remittance period for individual and consolidated reporting allow for a more streamlined process?
  • Question 4: What would be the impact if remittance dates for individual and consolidated reporting were different?
  • Question 5: When should audited figures be submitted?
  • Question 6: Are there any conflicts between prudential reporting deadlines and other reporting deadlines (e.g., statistical or fiscal)?

Regulatory Rationale and Background

• The CRD IV proposals (particularly the CRR) aim to apply Basel III across the EU and require the EBA to develop ITS on supervisory reporting.
• The Omnibus Directive mandated the EBA to develop these ITS, with the goal of reducing administrative burden and enhancing supervisory effectiveness.
• Historical Context: Prior to the CRR, supervisory reporting frameworks varied across Member States, leading to inefficiencies and increased costs for cross-border institutions.
• Accounting Frameworks: While the ITS does not aim to harmonise valuation measures, it acknowledges the lack of harmonisation in underlying accounting frameworks and seeks to align with existing standards such as IFRS and national accounting frameworks.

Conclusion

The EBA's draft ITS is a key step in the development of a single European rulebook for prudential reporting. It is designed to improve regulatory convergence, reduce reporting burdens, and enhance supervisory efficiency. The EBA is seeking stakeholder feedback to refine the standards and ensure they are practical, proportional, and effective. The finalisation and adoption of the ITS are timely, with a target submission date of 30 June 2012, to align with the CRR application date of 1 January 2013.