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Response to consultation to amend the ITS on procedures, forms and templates for resolution planning
Go backQuestion 1. Would the envisaged remittance date (31 May to be progressively advanced to 31 March) appropriate for all templates? If not, please justify your answer and indicate, template by template, the alternative remittance date you would suggest.
MT would prefer to keep the submission date as at end May, given that both the institutions and the Resolution Authority would need some time to familiarise with the new templates. Moreover, most institutions have the year-end as at December, and they will be still in the process of finalising their accounts during the first quarter of the year. However, as a compromise, MT can support to move the reporting date to end April.Question 2. Are there any technical obstacles or inconsistencies in the template ‘R 01.00 - Organisational structure (R-ORG)’ which would prevent you from, or make it disproportionate for you, to report the information required thereby?
NAQuestion 3. Are there any technical obstacles or inconsistencies in the second block of templates (R 02.00 - Liability Structure (R-LIAB), R 03.00 - Own funds (R-OWN), R 04.00 - Intragroup financial interconnections (R-IFC), major counterparties, R 06.00 - Deposit insurance (R-DIS)) which would prevent you or make it disproportionate for you to report the information required thereby?
The exercise to amend the EBA templates was useful and necessary to better reflect the data requirements for resolution purposes. However, it must be ensured that there is no duplication in the data requested in the EBA and SRB templates to avoid unnecessary burden on reporting institutions. Overlaps between the SRB and EBA templates exist in the current versions being used and the exercise conducted by the EBA provides the right opportunity to streamline the templates of the SRB and EBA.Question 5. The reporting of FMIs and information systems is already required since 2016. In practice are you operationally able to provide such view and do you think it is necessary to set a transition period, for example to progressively build up over the course of three years a full view of the systems within groups?
NAQuestion 4. Are there any technical obstacles or inconsistencies in the third block of templates (critical functions and core business lines, R 08.00 - Critical services (R-SERV), FMI services, critical information systems) which would prevent you or make it disproportionate for you to report the information required thereby?
NAQuestion 5. The reporting of FMIs and information systems is already required since 2016. In practice are you operationally able to provide such view and do you think it is necessary to set a transition period, for example to progressively build up over the course of three years a full view of the systems within groups?
NAQuestion 6. The reporting of FMI services and enabling services, in templates R 09.02 and R 09.03 could be facilitated if a list of typical services was included. Can you suggest such list?
NAQuestion 7. Does the nomenclature of information systems in template R 10-01 - Critical Information systems (General information) (R-CIS 1) cover the various types of existing systems, and would it in your view enable the authority to properly identify systems that are key in the performance of critical functions?
NAQuestion 8. Are the granularity and content of the revised templates appropriate with regard to investment firms? If not, please develop specific changes you would suggest in relation to investment firms.
NAName of organisation
Malta Financial Services Authority
