DZ BANK AG

In our opinion the representation of “Contributions to resolution funds and deposit guarantee schemes” as part of „Administrative expenses“ would be more appropriate. We can not identify the „operating“ caractere of the Contributions to resolution funds and deposit guarantee schemes. Thus, we would suggest „Administrative expenses“ for the representation.
The information is currently collected on an annual basis in accordance with IFRS reporting requirements. In our opinion, this annual collection is sufficient, since fluctuations are usually less volatile on a quarterly basis. Moreover, the compilation and reporting of this information on a more frequent basis means a large manual effort. The proportion between effort and benefit would not be reasonable.
More concrete definitions for table F 44.04 are needed. The references to the diverse EBA Guidelines and Directives do not seem to be clear enough. What should be reported e.g. for ‘identified staff'?

The information collected in this template is not primarly of an accounting nature. As a result, any data has to be collected outside of the accounting department, which will cause a new delivery process and therefore a higher coordination effort and a time consuming production process will be the consequence.
Furthermore, in our opinion it is not reasonable to collect this data in various EBA reportings. Reconciliation between the various EBA reportings will be required to insure synchronization. Even if the data is basically available, it does not fit with FINREP which is focused on accounting.
With the implementation of the new NPE/FBE-templates the view of credit-monitoring comes to the fore. Originally FINREP had the focus on accounting. The future mixtue of accouning and credit-monitoring will lead to a higher coordination and reconciliation effort, which will be highly time consuming. Furthermore, a costly change in the IT-setup will be required. Data are currently not available or hard to determine. The time line for the technical implementation is much too ambitious.

In general, in our point of view, it would be more reasonalbe to request all data concerning FBE/NPE in the context of a seperate FBE/NPE-reporting. Meanwhile, FBE/NPE-information is requested at several points – e.g. FINREP, EBA Guideline, ECB Guidline – with differing requirements. Harmonisation is needed. Centralisation in one single reporting would be more efficient.
The information collected in this template is not primarly of an accounting nature. As a result, any data has to be collected outside of the accounting department, which will cause a new delivery process. Higher coordination effort and a time consuming production process will be the consequence.
Alexander Kern