Response to consultation on Guidelines on ICAAP and ILAAP information

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1) 1. What are your views on the scope and specification of information to be collected for the purposes of the assessment of ICAAP and ILAAP under SREP specified in the draft Guidelines?

In many of areas, such as information on business models, coverage by IT systems, information to be collected for ICAAP and ILAAP is requested by the EBA for each subsidiary or group entity. In January 2014, EBA issued its recommendation regarding the use of LEIs for supervisory reporting. If ICAAP and ILAAP fall under the category of supervisory reporting, then reporting for ICAAP and ILAAP already would require the use of LEIs for these entities in the reports to the EBA from the reporting institutions.

2) 2. What are your views on the general criteria for the organisation of the collection of ICAAP and ILAAP information as specified in Section 4 of the draft Guidelines?

Not applicable. Comments provided on behalf of GLEIF are limited to the use of LEIs in regard to reporting to the EBA.

Name of organisation

GLEIF(Global Legal Entity Identifier Foundation)