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

Question 1: Are the instructions and templates clear to the respondents?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

Question 2: Do the respondents need further clarification to understand which of the minimum reporting obligations would apply to their specific profile (Resolution entity, Liquidation entity, RLE, non-institution…?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

Question 3: Do the respondents identify any discrepancies between these templates and instructions and the determination of the requirements set out in the underlying regulation?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public 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

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

▪ explain the nature/source of the cost (i.e. explain what makes it costly to comply with this particular element of the proposal) and specify whether the cost arises as part of the implementation, or as part of the on-going compliance with the reporting requirements

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

▪ offer suggestions on alternative ways to achieve the same/a similar result with lower cost of compliance for you

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

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

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

i. Do you have any comment on the changes in the definition of the RLE threshold, including the absolute threshold of 5 billion EUR?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

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?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

ii. Do you see an issue in the ability of the group to identify the resolution group to which each entity reported in the organizational structure belongs?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

i. Are the data-point definitions provided for reporting of the Carrying Amount sufficiently clear?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

ii. Do the revised data points for the reporting of Own Funds by Investment Firms better correspond to the reporting obligations for these types of Institutions? If not, please elaborate what changes you deem appropriate.

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

iii. Do you anticipate any difficulties in providing the additional data required for the reporting of intragroup financial connections (for liabilities excluded from bail-in)?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

iv. Do you see merit in providing additional clarification about any data-point definition existing in the previous version of the CIR on Resolution Reporting? If so, for which specific data points?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

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

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

ii. Do you find the availability of a comments section useful to explain your assessment of the critical functions? Would you suggest another means of doing this, and if so, what?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

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

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

ii. Do you think that that the data request on relevant services, as covered in the revised ITS, is sufficiently clear?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

iii. Do you see any overlap between this data request and related data requests on relevant/critical services raised by your Resolution Authority as part of the resolvability assessment?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

i. Is the definition of “substitutability” provided in the new reporting on Alternative CCP providers (Z09.04 c0030) sufficiently clear? If not, what clarifications do you think would be necessary?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

ii. Are there additional or modified data points that you propose to include in Z09.03 to adequately capture the activity of the reporting entity with FMI service providers?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

iii. Are the instructions across Z09.01-Z09.04 sufficiently clear and detailed, and if not, what clarifications do you think are necessary and where?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

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?

Please refer to the uploaded PDF (EBF_046616) with the title "EBF response to the EBA/CP/2024/18 - Public consultation on draft Implementing Technical Standards overhauling the EBA resolution planning reporting framework".

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

Question 1: Are the instructions and templates clear to the respondents?

Question 2: Do the respondents need further clarification to understand which of the minimum reporting obligations would apply to their specific profile (Resolution entity, Liquidation entity, RLE, non-institution…?

Question 3: Do the respondents identify any discrepancies between these templates and instructions and the determination of the requirements set out in the underlying regulation?

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

▪ explain the nature/source of the cost (i.e. explain what makes it costly to comply with this particular element of the proposal) and specify whether the cost arises as part of the implementation, or as part of the on-going compliance with the reporting requirements

▪ offer suggestions on alternative ways to achieve the same/a similar result with lower cost of compliance for you

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

i. Do you have any comment on the changes in the definition of the RLE threshold, including the absolute threshold of 5 billion EUR?

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?

ii. Do you see an issue in the ability of the group to identify the resolution group to which each entity reported in the organizational structure belongs?

i. Are the data-point definitions provided for reporting of the Carrying Amount sufficiently clear?

ii. Do the revised data points for the reporting of Own Funds by Investment Firms better correspond to the reporting obligations for these types of Institutions? If not, please elaborate what changes you deem appropriate.

iii. Do you anticipate any difficulties in providing the additional data required for the reporting of intragroup financial connections (for liabilities excluded from bail-in)?

iv. Do you see merit in providing additional clarification about any data-point definition existing in the previous version of the CIR on Resolution Reporting? If so, for which specific data points?

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

ii. Do you find the availability of a comments section useful to explain your assessment of the critical functions? Would you suggest another means of doing this, and if so, what?

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

ii. Do you think that that the data request on relevant services, as covered in the revised ITS, is sufficiently clear?

iii. Do you see any overlap between this data request and related data requests on relevant/critical services raised by your Resolution Authority as part of the resolvability assessment?

i. Is the definition of “substitutability” provided in the new reporting on Alternative CCP providers (Z09.04 c0030) sufficiently clear? If not, what clarifications do you think would be necessary?

ii. Are there additional or modified data points that you propose to include in Z09.03 to adequately capture the activity of the reporting entity with FMI service providers?

iii. Are the instructions across Z09.01-Z09.04 sufficiently clear and detailed, and if not, what clarifications do you think are necessary and where?

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?