Response to cP on GLs Guidelines on harmonised definitions and templates for funding plans of credit institutions

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1.1 Do respondents agree with the proposed breakdown of “Total long-term unsecured (original maturity >=1 year)”?

No

1.2 Otherwise, which breakdown would you suggest?

No

Template P02.02 has been expanded to include additional public sector and Central Bank sources of funding. Do respondent believe that now this template covers all forms of public sector and central bank sources of funding or should additional forms of sources be included?

No

3.1 Do respondents agree that information on currency breakdown after hedging (template P02.06) will provide effective insight into possible currency mismatches?

Yes, although the proposal is that if a bank removes FX risk by applying FX hedging except for unwinding of hedges to minimize volatility in group CET1 ratio, it may indicate this by “Y”. What follows is that if an institution applies “N”, then templates needs to be populated.

3.2 Does the information reflect banks’ FX management approac more information to better reflect banks’ FX management?

No, there is no need to request more information.

3.3 Are the instructions are clear enough?

NA

3.4 If the instructions are not clear please indicate how they could be improved.

NA

Do respondents agree with the possibility to have “retained issuance” for each of the instruments included in template P05.00? If not, could you please indicate which ones should be maintained and which ones should not and the reasons for it?

We consider this unnecessary, as retained issuances do not add increased risk to the balance sheet.

5.1 Which methodology do you apply to calculate carrying amounts for future issuances (please describe as detailed as possible and highlight any problem with that calculation)?

Fixed carry amounts as per start point is applied where future values are adjusted based on start point value (which includes carry amount) minus maturating nominal volumes, plus nominal issuance volumes.

5.2 Are you of the opinion that reporting maturing and new issuance volumes (as defined in P 05.00) as nominal amounts would better reflect your planning procedure and approach and do you believe that this alternative is preferable?

Approach as per 5.2 is seen as the preferred treatment.

6.1 Do respondents believe that these movements could occur too often or be big enough so that including them as inflows or outflows as explained above and in the instructions may distort the analysis of the information?

Item seen as NA or as not big enough to change logic in the reporting template.

6.2 If the answer to the 6.1 is positive, which would be the best way for the respondents to report this information?

NA

7.1 Do respondents agree with amending the templates to align definitions with FINREP? Are there other definitions that could be further aligned with other parts of the EBA supervisory reporting framework?

Alignment with FINREP is seen as positive.

7.2 Do respondents agree that alignment of definitions will facilitate reporting production process?

Yes, we do agree.

7.3 Are there other aspects in the template design or further integration with FINREP reporting technical package that could help in data production process?

NA

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