Response to consultation on Implementing Technical Standards on amended disclosure requirements for ESG risks, equity exposures and aggregate exposure to shadow banking entities
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1. Do you have any comments on the proposed set of information for Large institutions?
NO
2. Do you have any comments on the simplified set of information for Other listed institutions and Large subsidiaries?
NA
3. Do you have any comments on the simplified set of information proposed for SNCI and other non-listed institutions?
NA
4. Do you have any comments on the proposed approach based on materiality principle to reduce the frequency (from semi-annual to annual) of specific templates (qualitative, template 3, and templates 6-10) for large listed institutions?
NO
5. Do you have any comments on the transitional provisions and on the overall content of section 3.5 of the consultation paper?
Yes, please see the attached document
6. Do you have any comments on the proposed amendments to Table 1 and Table 3?
NO
7. Do you have any further suggestions on Table 1A?
NA
8. Do you have any comments on the proposed additions and deletions to the sector breakdown?
Yes, please see the attached document
9. Do you have any views with regards to the update of the templates to NACE 2.1?
Yes, please see the attached document
10. Do you have any views with regards to NACE code K – Telecommunication, computer programming, consulting, computing infrastructure and other information service activities, and in particular K 63 - Computing infrastructure, data processing, hosting and other information service activities, whether these sectors should be rather allocated in the template under section Exposures towards sectors that highly contribute to climate change?
Yes, please see the attached document
11. Do you have any comments on the inclusion of row “Coverage of portfolio with use of proxies (according to PCAF)”?
NO
12. Do you have any further comments on Template 1?
Yes, please see the attached document
13. Do you have any comments or alternative suggestions for SNCIs and other institutions that are not listed, regarding the sector breakdown?
NA
14. Do you have any additional suggestions how to adjust Template 1A for SNCIs and other institutions that are not listed?
NA
15. Do you have any further comments on Template 1A?
NA
16. Should Template 2 in addition include separate information on EPC labels estimated and about the share of EPC labels that can be estimated?
NO
17. Should rows 2, 3 and 4 and 7, 8 and 9 for the EP score continue to include estimates or should it only include actual information on energy consumption, akin to the same rows for EPC labels?
NO
18. Do you have any comments on the inclusion of information on covered bonds?
NO
19. Do you have any comments on the breakdown included in columns b to g on the levels of energy performance?
NO
20. Do you have any further comments on Template 2?
Yes, please see the attached document
21. Do you have any comments on Template 3?
Yes, please see the attached document
22. Do you have any comments with the proposals on Template 4 and the instructions?
NO
23. Do you have any views on whether this template could be improved with some more granular information in the rows, by requesting e.g. split by sector of counterparty or other?
NO
24. Do you have any further comments on Template 4?
NO
25. Do you have any comments on the proposal using NUTS level 3 breakdown for Large institutions and NUTS level 2 for Other listed institutions and Large subsidiaries? Would NUTS level 2 breakdown be sufficient for Large institutions as well?
Yes, please see the attached document
26. Do you have any comments on the instructions for the accompanying narrative and on whether they are comprehensive and clear?
NO
27. Do you have any further comments on Template 5 and on its simplified version Template 5A?
Yes, please see the attached document
28. Do you have any comments on the proposal to fully align templates on the GAR, that is, templates 7 and 8, with those under the Taxonomy delegated act by replacing the templates with a direct cross reference to the delegated act?
Yes, please see the attached document
29. Do you have any comments on the proposal related the BTAR and to keep it voluntary?
Yes, please see the attached document
30. Do you have any comments regarding the adjustments to template 10?
NO
31. Do you have any further comments on the Consultation Paper Pillar 3 disclosures requirements on ESG risk?
Yes, please see the attached document
32. Are the new template EU SB 1 and the related instructions clear to the respondents? If no, please motivate your response.
NA
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?
NA
34. Are the amended template EU CR 10.5 and the related instructions clear to the respondents? If no, please motivate your response.
NA
35. Do the respondents agree that the amended template EU CR 10.5 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?
NA
36. Do the respondents consider that the “mapping tool” appropriately reflects the mapping of the quantitative disclosure templates with supervisory reporting templates?
NA
Attachment
Banca Transilvania (RO)_Questions_0.xlsx
(25.46 KB)