Response to consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework

▪ specify which element(s) of the proposal trigger(s) that particularly high cost of compliance

Yes, we identify such elements. Our concerns generate much bigger requirements in Z07.01 with different templates concerning different economic function (different for deposits and credits) and new Z.10 including all templates with granular indication of liabilities are to be written off or to be restructured.

i. How does this change impact your organisation’s ability to report resolution data in a timely manner while still retaining data quality?

The proposal to change the submission date is a major concern for reporting institutions. It would have a substantial negative impact, resulting in an increased reporting burden and cost on banks.

Bringing forward the submission date by one-month results in a substantial increase of workload for teams that are already responsible, besides the collection of additional granular data, for producing several other reports since the submission date interferes, among others, with the annual results, annual report and prudential supervisory reports including ICAAP and ILAAP and (at least bi-annually) with the EBA stress test.

i. Do you identify any issues with expanding the scope of Z01.01 to all entities in the group, bearing in mind that this report would only be requested at the level of the Group?

Banks indicate also that the draft impose on them bigger scope of companies included in the reporting requirements presented in three form of consolidation: financial consolidation, consolidation for prudent context and for resolution group makes the needed analyses much extended and it should be done in shorter time horizon.

i. Do you have questions on how the new instructions on Onboarding Capacity should be interpreted for your organization?

We have doubts about the situation of the company being the part of resolution group which is obliged to complete Z.07.01 on individual basis according to the proposed amendment of regulation 2018/1624, but this company does not play the critical function (according to decision of competent authority). Is this company obliged to fulfil this requirement in this situation?

i. Do you see any issue in identifying “relevant services” as defined in the revised ITS?

Banks suggest intra-enitity relevant services not to be reported by entities for which the preferred resolution tool is Bail-in - to reduce the reporting burden. It seems that for entities with transfer tools as alternative resolution tool the identification of intra-entity relevant services could be carried out under the assessment of interconnections performed in line with EBA Guidelines on transferability to complement the resolvability assessment for transfer strategies.

i. Are the data-point definitions provided for reporting of the Granular Liability Data sufficiently clear? If this is not the case, for which data points would you require additional clarifications?

Our concerns generate much bigger requirements in Z07.01 with different templates concerning different economic function (different for deposits and credits) and new Z.10 including all templates with granular indication of liabilities are to be written off or to be restructured.