Response to 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…?

LDR: Regarding the removal of duplicated data points: does this imply that certain data points will be left blank in ITS reporting? For example, RWA, capital buffers, and SREP requirements are data points found in both the new ITS and COREP. Why not consider in the Data Model the possibility to automatically populate these data points from COREP/FINREP to ITS?

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

• Given the EBA’s efforts to harmonize reporting requirements with the SRB and RA, can the new framework be a starting point to alleviate the reporting burden on the parent resolution entity for non-BU banks within the same consolidation scope?
• Since there is no direct correlation between LDR data templates and the others (CIR, FMI, CFR, etc.), can the reporting package (templates) be split into two reports: one containing the templates included in the SRB LDR report and the other containing the rest? This would prevent unnecessary dependencies and reduce the likelihood of increased resubmissions.
• A one-year implementation time increases the operational burden on banks. We encourage the EBA to consider the substantial internal changes required to comply with the new framework and to allow banks sufficient time to implement the new reporting templates.
• It would be helpful to receive an official reporting obligations waiver from the SRB once the final framework is published by the EBA.

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?

Granular Liability Data_Intragroup Liabilities: This reporting obligation is essentially limited to Resolution entities at the Individual level to reduce the reporting burden on banks - does it mean there will not be Intragroup liabilities reported on resolution group level?