Response to discussion on Technical Advice on selected KPIs under the Taxonomy Disclosures Delegated Act under Article 8 of the Taxonomy Regulation
Q1. Please identify your organisation (if applicable) and indicate the capacity in which you are responding to this consultation:
b. preparer of sustainability informationQ2. Do you agree with the analysis presented?
Yes
In your response, where applicable, please assess whether voluntary disclosure of this KPI would be meaningful and feasible, and hence should be considered.
Option a. F&CI KPI is discussed to be not relevant, not comparable and very complex to report on for financial institutions.
Voluntary disclosures never work in my opinion and should hence not be further considered
Q4. Should additional items from FINREP Template 22.1 also be included in the revised KPI? Please consider in particular that (i) have been assessed as unrelated to capital market activities, e.g. ‘custody and other related services’, and (ii) those that have not been mapped to the Fees and Commissions KPI, such as ‘structured finance’, ‘loans granted’, ‘commodities’.
NA as option a is choosen
Q5. Do you have evidence and/or arguments on potential costs and benefits associated with disclosing the Fees and Commissions KPI?
See above, large costs and small benefits since disclosing on F&CI KPI will not add insight for the reader of the information on the "sustainability" of a financial institution.
Q6.Do you agree with the analysis presented?
Yes
In your response, where applicable, please assess whether voluntary disclosure of this KPI would be meaningful and feasible, and hence should be considered.
Option a. Very complex to retrieve trading book information, low added value to the reader
Q8. Do you have evidence and/or arguments on potential costs and benefits associated with disclosing the Trading Book KPI?
See above
Q9. Do you agree with the analysis presented and the conclusion to narrow down the investment firms’ KPI?
NA, option a choosen
Please explain if you think that other services, e.g. execution of orders on behalf of clients, should be included in the revised KPI.
No, option a choosen. IF scope is narrowed down, very complex for a CI to identify what for example is meant with "Portfolio management" or "Investment advice", making reporting on this KPI very random and hence not comparable to other Banks at all.
Q11. Do you consider it more appropriate for the KPI to reflect the value of assets covered by the investment services rather than the monetary benefits generated?
I dont understand this question, sorry
Q12. Do you agree with the analysis presented and the conclusion to align the grandfathering rules with the approach set out in EU Green Bond Regulation?
YEs
Q13. Do you agree with the analysis presented and proposed conclusions?
Yes
i. Should the KPI disclosed by the parent undertaking, reflecting the group’s main or prevalent activity, be used? If not, what alternative methodology should be applied?
Main activity
ii. In the case of a credit institution-led group, such as a financial conglomerate, should the consolidated KPI disclosed by the parent undertaking also incorporate the assets of the insurance (and non-financial) undertaking, rather than accounting for the insurance (and non-financial) undertaking solely through the equity method? Please justify your answer in terms of feasibility, usability and transparency of sustainability information.
No specific opinion. Would like to report on the core business of the consolidation, and not on the separate non-material subsidiaries if they are other types of financial undertakings (investement firm, asset manager etc)
Q15. Which KPIs you do think are necessary and should be required for groups with mixed activities where the credit institution is the parent company such as credit institution-led financial conglomerates, credit institution-led financial holding companies and relevant mixed financial holding companies?
Only GAR
Q16. Do you agree with the analysis presented and the conclusion that OpEx financing should not be explicitly incorporated in the methodology for calculating financial undertakings’ KPIs? Please provide your rationale for supporting the explicit inclusion of provisions allowing financial undertakings, on a voluntary basis, to use the OpEx KPI disclosed by their counterparties when calculating their own KPIs.
Yes. OPEX not relevant for FI's and hence no added value of reporting
Q17. Should the credit institution’s AuM KPI (Annex V) and the KPI for asset managers (Annex II) be merged? Please explain why and how, including the content of the information that should be retained in a potential merged KPI.
No
Q18. What are your views on the design of off-balance sheet item reflecting financial guarantees to financial and non-financial undertakings in a potential merging of the asset management activities as presented?
No specific opinion.
Q19. Do you have any additional comments or suggestions to improve, simplify or clarify the disclosure requirements within the scope of this Call for Advice, including through redrafting of instructions, and clarification of definitions, or the streamlining of terminology?
No