Response to consultation on Implementing Technical Standards on amended disclosure requirements for ESG risks, equity exposures and aggregate exposure to shadow banking entities
32. Are the new template EU SB 1 and the related instructions clear to the respondents? If no, please motivate your response.
We seek confirmation from the EBA that aggregated shadow banking exposures should be reported considering individual counterparty exposures, not exposures for a “group of connected clients” (as used for large exposure purposes). Our understanding is that CRR requires reporting the sum of exposures identified at the individual counterparty (i.e. shadow banking entities) level.
33. Do the respondents agree that the new template EU SB 1 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?
It would be helpful to introduce materiality thresholds at counterparty level for disclosing shadow banking entity exposures, since the setting of a single materiality threshold will guarantee a level playing field ensuring comparability among outcomes.
Furthermore, since the Shadow Banking definition according to Commission Delegated Regulation (EU) 2023/2779 includes different type of counterparties with different risk profiles, it would be helpful to split up the total aggregate exposure according to the main categories of shadow banking entities (i.e. Money Market Funds, Alternative Investment Funds, other Not – Supervised Financial Entities (which includes Banks that fall behind Supervisory Regulations not compliant with Basel Principles)