Response to consultation on draft Implementing Technical Standards (ITS) on disclosure for leverage ratio

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Are the instructions provided in annex 2 on the breakdown of leverage ratio exposure of LRCom and LRSpl sufficiently clear? Should the instructions for some rows be clarified? Which ones in particular? Are some rows missing?

• Regarding the different weights used for the off-balance sheet exposure in template LRCom (rows15-17) we note that these are different to the weights used in the supervisory reporting templates;
• Regarding the requirement to report both point-in-time and quarterly average leverage ratio we ask the EBA to require only a point-in-time figure until the leverage ratio is finalised and becomes a legal requirement in 2018 as the calculation will be subject to change during the review period;
• Regarding article 499.2 we note that the CRR provide institutions with the option to disclose the information on leverage ratio based on just one or both of the definitions of the capital measure. However, LRCom limits this choice by only enabling one of the measures to be disclosed;
• Regarding LRQua we ask what needs to be disclosed in terms of internal strategic decisions and processes impacting leverage ratios as there are concerns within the industry that this will require financial industry to disclose information that is difficult to directly link to leverage ratio and which in addition could be sensitive.
We hope that only general information or information already disclosed is required, for example:
- General information: disclosing the process that was set up to follow the leverage ratio;
- Information already disclosed such as strategic decision taken which has led to a change in the leverage (these decisions should normally have already been described in a press release, if significant).

Our analysis shows that no impacts incremental to those included in the text of the Level 1 text are likely to materialise. Do you agree with our assessment? If not please explain why and provide estimates of such impacts whenever possible.

If the disclosures will mainly be based on reporting data, we agree that there will not be any large additional costs for setting up this new requirement. There will however be an additional burden on human resources during the period prior to finalisation of the leverage ratio definition due to the manual input to the templates.

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Name of organisation

European Savings and Retail Banking Group aisbl / World Savings and Retail Banks Institute aisbl