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EBA should align their requirement with the EDTF recommendations.
We believe IFRS 7 gives comprehensive details on these assets, and it is not necessary to go beyond these requirements.
It would be far preferable to use period end data rather than median values to ensure consistency with the COREP framework.
We do not have any view on this question.
We are satisfied with the current format of template B
We do not have any views on this.
We think it is very important that information at point in time is better than median from process, cost and amount of work required to accomplish the desired information
We are usually in favour of the prescriptive guidelines as to narrative information required under template D so that there is consistency among the reporting institution.
We suggest that such disclosure should be published with the financial statements as not disclosing such information will be against the Corporate Governance Code which places a duty on directors to present a fair and balanced assessment of the firm’s position which could not be provided if the institution was heavily encumbered at time of presenting financial statements
Vikas Gupta