We do not have comments on the structures presented in Section 5.1.2.
Reporting may be challenging as it can be difficult to identify the relevant exposures such as promotional loans from public development banks. In this context, we would welcome if the EBA could make available a list of entities that meet the definition of a public development bank.
The largest components of the leverage ratio susceptible to significant temporary volatility in volume during the quarter are (a) SFTs and (b) Other Assets. The SFT component is volatile as it is based purely on market demand at any given point of time. The item Other Assets includes debt securities, treasury bills and cash and bank balances with central banks. Cash is inherently volatile and movement on debt securities is based on market yields and liquidity demands.
The least susceptible component is the Tier 1 Capital.
While such an alignment is feasible in the reporting systems, we would question whether this alignment would be desirable in terms of costs and benefits. We would find it useful to understand what additional value the EBA expects from this presentation of RWEA.
There are clearly resource implications of the proposed change to pre-CRM exposures in this template. At the same time, we consider the value added of this presentation to be limited. For reasons of consistency, we would prefer to keep reporting requirements in line with RWEA reported in CA2.
Yes, overall the templates and instructions are clear.
No, we have not identified any discrepancies between the templates and instructions and the calculations of the requirements set out in the underlying regulation.
Yes, overall we consider the amended ITS fit for purpose.