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报告摘要

Summary of Comments to "Consultation Paper on Financial Reporting" (CP06) – April 2005

Core Content

The Czech Banking Association and the Czech National Bank provided detailed comments on the Consultation Paper on Financial Reporting (CP06), published in April 2005, as part of the formal consultation process. The comments focus on improving the clarity, consistency, and practicality of the proposed financial reporting framework, particularly in alignment with IFRS standards and operational realities of banks.

Main Views and Key Information

General Comments

Joint Comments of the Czech Banking Association and the Czech National Bank

Redundant Information: The proposal includes duplicate information in balance sheets and profit and loss statements. They recommend consolidating to the highest level of aggregation and placing detailed data in separate tables.
Common Practice vs. IFRS: The use of "common practice" in some areas is inconsistent with IFRS. For instance, the exclusion of interest income from financial assets held for trading under IFRS is not aligned with the proposal.
Accrued Interest Disclosure: The concept of "accrued interest" as a separate line is not supported, as it is part of the carrying amount of financial instruments. They refer to ED 7.10 for a clear IFRS-based approach.

Separate Comments of the Czech Banking Association

Excessive Detail: The proposed framework is too detailed and may not be necessary. The full set of tables should replace annual financial statements, which is impractical for non-annual reporting.
Operational Burden: Implementing the full set of tables in routine operations would create a significant burden on banks, especially due to the lack of data availability in IT systems.
Sector-Based Fair Value Reporting: The proposal requires fair value disclosure by sectors, which is not in line with IFRS requirements (which use categories of financial assets and liabilities). This may be problematic for data collection and consistency.
Sector-Based Asset/Liability Division: The division of assets and liabilities by counterparty sectors is not supported, as it is not required by IFRS and may complicate reporting.

Separate Comments of the Czech National Bank

Sector Classification Misalignment: The sector classification in the proposal does not match ESA 95, leading to potential inconsistencies in monetary and financial statistics.
Resident/Non-Resident Data: The Czech National Bank emphasizes the need for data on residents and non-residents, as required by the IMF's Coordinated Compilation Exercise (CCE) for Financial Soundness Indicators (FSIs).

Special Comments by Table

Table 1.1 Consolidated Balance Sheet – Assets

Category "Financial assets held for trading": Line "Debt instruments issued by" should be changed to "Debt securities issued by".
Category "Financial assets designated at fair value through profit and loss": Same change as above.
Category "Available-for-sale financial assets": Same change.
New Category: "Investments in subsidiaries, associates and joint ventures measured at fair value" should be added.
Category "Loans and receivables": Line "Unquoted loans and advances" should be changed to "Loans and advances".
Category "Held-to-maturity investments": Line "Quoted debt instruments issued by" should be changed to "Debt securities issued by".
Category "Accrued interest income": Should be deleted, as accrued interest is part of the carrying amount.

Table 1.2 Consolidated Balance Sheet – Liabilities

Structure Inconsistency: The structure of "Financial liabilities held for trading" and "Financial liabilities designated at fair value through profit and loss" is inconsistent with Table 18.
Subordinated Liabilities: The line "Subordinated liabilities" should be deleted and consolidated before "Provisions".
Deposits from ...: Should be renamed to "Liabilities to ...", as liabilities are broader than deposits.
Accrued Interest Expenses: Should be deleted, as it is part of the carrying amount.

Table 1.3 Consolidated Balance Sheet – Equity and Minority Interest

Operational Recommendation: Join Table 1.2 and Table 1.3 for operational efficiency.

Table 2 Consolidated Profit and Loss

Text Clarification: Remove "only interest flows" and "(excluding interest flows)".
Renaming Categories: "Interest net income" → "Net Interest income"; "Fee and Commission net income" → "Net Fee and Commission income".
Interest Income/Expense: Lines related to "Derivatives used for hedging" in interest income and expense should be deleted.
Gains and Losses: Gains and losses from derivatives should be separated from those of other instruments.

Other Tables

Tables 7, 8, 19, 20, 21, 22: Excessive detail compared to ED 7.26.
Table 9: Similar structure to Table 4 is recommended.
Table 10: Should be deleted.
Table 12.B: Column "Fair value" is not relevant for all lines.
Table 17: Should be deleted.
Table 18: Parts A and B should be split into separate tables (18 and 19).
Table 22: Should be deleted.
Table 26: Sector principle is not supported by the Czech Banking Association.
Table 28: Excessive detail on related party transactions; some information may not be available.
Table 30: Table A is redundant and should be deleted.
Table 32: Gains and losses in hedge accounting should not be divided.
Table 36: New lines "Audit fees", "Tax advisory fees", and "Legal and other professional fees" are not supported.
Table 39: Columns like "Maximum credit exposure" are not well-defined; Table D should include all credit exposures.
Table 40 and 41: Maturity structure should be harmonized; include "Total interest sensitivity gap".
Table 41: Separate lines for banking book and trading book are recommended.
Table 44A: Definition of "key management" is unclear.
Table 48: Structure should be aligned with Table 1.3; a standardized statement of changes in equity is recommended.

Conclusion

The comments highlight the need for consistency with IFRS, practicality in implementation, and clarity in definitions and structures. They emphasize that the proposed reporting framework may be too detailed, inconsistent with existing standards, and burdensome for banks. Both the Czech Banking Association and the Czech National Bank advocate for a balanced approach that maintains transparency while ensuring operational feasibility.

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