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It should.
The requirements in para. 8 appear unnecessary verbose, please streamline.
Para 10 should require more detailed requirements regarding the summary description. Perhaps the summary could address the points mentioned in para 8.
Please see next answer.
This Title is confusing, e.g. para 12 e. assumes that materiality is a 'user-centric concept,' but 12. g mentions that materiality should be an 'institution-specific concept.'
These terms should be defined.
In addition, para 14 b. appears to allow banks to disclose less if that is appropriate in given political environment, this is unclear, please clarify.
Perhaps this Title could align itself with the International Standard on Auditing (ISA) 320, “Audit Materiality”, which offers more consistency.
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The suggested indicators are set at very high levels, thus allowing many banks to disclose only at low frequencies. Instead of concentrating on size, one should consider the frequency that banks apply to publishing semi-annual financial reports or interim reports (audited or non-audited) as a minimum frequency. This will likely align with investors' expectations and user demands.
Regarding the proper measures of size, they cover a limited number of banks, which gives the wrong signal. The cut-offs in para 18 a-d. should be lower, so much lower that they cover at least a significant majority of banks (75%).
Please see next answer.
Para 19 should provide more accurate requirements than it currently does. Para 19.b and 19.c, for example, are unclear on what they expect regarding the reasoning for non-disclosure or the general or aggregate substituting information.
It would help if banks reveal separately which information is left undisclosed for proprietary reasons and which information is left undisclosed for confidentiality reasons.
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One should consider the frequency that banks apply to publishing semi-annual financial reports or interim reports (audited or non-audited) as a minimum frequency.
The day before perhaps?
One thing EC / EBA should really consider is to require banks to submit their disclosures in a singe repository like is the case for U.S. bank holding companies. This would make research into banks much more easy. See http://capitalissues.co/2014/08/02/a-python-script-to-manage-regulatory-data-of-u-s-bank-holding-companies/
Cetier the First