Response to consultation on ITS on Supervisory Reporting amendments with regards to FINREP
Go back
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.
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.
Question 1 (on template F 02.00) Do respondents agree with the proposed FINREP representation of “Contributions to resolution funds and deposit guarantee schemes” as part of “other operating expenses”? If not, which representation would you suggest?
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.Question 5 (on F 40.01, F 40.02) The information included in the two group structure templates is currently collected on an annual basis. Without prejudice to notification obligations under national laws, a more frequent collection (quarterly) would improve the timely reflection and awareness of changes to institutions’ group structures. Which benefits and challenges with regard to the compilation and reporting of this information on a more frequent basis do you envisage?
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.Question 6 (on F 44.04, F 48.00) Some of the items included in templates F 44.04 and F 48.00 are also collected for the purposes of benchmarking in accordance with EBA’s Guideline on the remuneration benchmarking exercise (EBA/GL/2014/08). The items requested in FINREP are of high-level nature and full alignment has been sought to keep the reporting burden limited. What is your view on the inclusion of this information in FINREP? Do you see any inconsistencies between this data and the data collected in accordance with the GL on remuneration benchmarking exercise that impact the reporting burden?
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.
Question 7 (on several templates, see F 23.01 – F 23.03) The following templates (templates F 23, F 24, F 26, F 47) request information on loans and advances subject to definition of non-performing and forborne exposures (with the exception of loans and advances classified as held for sale), in contrast to F 18 and F 19 that cover ‘exposures’ in a broader sense, e.g. also debt securities. The rationale behind applying these additional templates to loans and advances only is that the majority of exposures in credit institutions’ balance sheets that turned non-performing are loans and advances. To have risk based focus to monitor evolution of asset quality and to balance reporting burden the templates focus on loans and advances only. Are the definitions and instructions on the definition of the scope clear?
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.