Response to consultation Paper on specific supervisory reporting requirements for market risk
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that the first reference date is 30 June 2021.
This would align the first reference date with the other projected COREP first reference dates.
This will enable institutions moving to the Alternative Standardised Approach to Market Risk, to implement all changes to the COREP reporting requirements to the same
timeframe, and to provide a sufficient period for design and testing of systems and software used for reporting purposes.
We would therefore recommend that in Recital (5) and Article 6 of the draft ITS, the date of “1 March 2021” is replaced by “1 June 2021”. If this change is made, the
derogation in Article 6 would no longer be required.
We have provided some general comments, and suggested some drafting changes, in our submitted letter.
Question 1. The ‘thresholds’ template requires a breakdown of the ‘on- and off-balance sheet business subject to market risk’ into on-balance sheet and off-balance sheet business. Is that breakdown clear, or would you need ad-hoc definitions for differentiating ‘on-balance sheet items’ from ‘offbalance sheet items’ to ensure a proper implementation of the reporting requirements? Are there particular challenges or a burden involved in differentiating between on- and off- balance sheet items?
BNY Mellon’s main concern in relation to the draft ITS is the application date of the requirements. We recommend that the application date is changed to 1 June 2021, sothat the first reference date is 30 June 2021.
This would align the first reference date with the other projected COREP first reference dates.
This will enable institutions moving to the Alternative Standardised Approach to Market Risk, to implement all changes to the COREP reporting requirements to the same
timeframe, and to provide a sufficient period for design and testing of systems and software used for reporting purposes.
We would therefore recommend that in Recital (5) and Article 6 of the draft ITS, the date of “1 March 2021” is replaced by “1 June 2021”. If this change is made, the
derogation in Article 6 would no longer be required.
Question 2. Are the scope and level of application of the reporting requirements and the content of the templates and the instructions clear?
Subject to our response to question 1, we did not have any further comments.We have provided some general comments, and suggested some drafting changes, in our submitted letter.