Združenje bank Slovenije (The Bank Association of Slovenia)
We do not see any additional benefits for quarterly reporting of tables F 40.01 and F 40.02 as Slovenian banks (and banks in general) do not have material changes in group structure on such a frequent level. Also these two tables are prepared manually, which means additional time and resources are required for preparation and control.
Data for the tables F 44.04 and F 48.00 are not directly available in General ledger and also are not prepared or monitored in Accounting department. From this point of view and given the additional costs incurred we suggest that this table should be excluded from FINREP reporting.
Data reported in tables F 23, F 24, F 26 and F 47 include data regarding non-performing, forborne exposures and collateral. These data are not available in General ledger and are also are not prepared or monitored by Accounting department. Usually these data is are prepared and reported in Risk department. Also we would like to point out that in these tables will be reported detailed information will be reported which is highly granular and not all available automatically, so additional manual inputs will be necessary and thus additional costs will incur. For these reasons and taking into consideration the lack of added value we suggest that these tables should be excluded from FINREP reporting.
Please also consider for excluding the tables F 18 and F 19 if these two table would be excluded from FINREP reporting and would be reportedto report them together with above mentioned tables.
Data for the table F 48.00 are not directly available in General ledger and are also are not prepared or monitored in Accounting department, ; from this point of view we suggest that this table should be excluded from FINREP reporting.