Austrian Federal Economic Chamber, Division Bank and Insurance
Although a standardized reporting is in general preferred compared to an ad hoc reporting which (slightly) changes for each reporting period, the cost of implementation for the proposed templates will be disproportionately high. It requires a huge IT change, as the reporting of FINREP and the reporting of COREP has to be merged. Not only IT efforts, but also a recurring production need will cause additional FTEs on both sides – accounting and regulatory reporting - in order to work together. The implementation of the sovereign templates as proposed within COREP reporting, using FINREP information will require combining both technical and procedural aspcects, which is new, complex and costly.
Another aspect is the reporting deadline. It would reduce the burden, if these templates would not have the same reporting deadline as all other COREP templates and would be due at least two weeks later.
A threshold is welcome and appropriate.
There is not much of a difference.
Generally the rows are defined as exposures according to the CRR, whereas in the columns all the amounts are defined according to FINREP. Which amounts would be needed at the end in the reports C 33.01 and C 33.02?
If the values either from COREP or from FINREP templates will be taken (Exposure or Carrying value), it cannot be compared or reconciled to each other.
It is not clear how IMM Netting has to be handled. In COREP netted future expected exposure values are reported, where FINREP does not have such netting and such values.
Furthermore it is not clear how in template C33.02 the residual maturity for cross product netting should be reported, as for cross product netting this information is not available.