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IBM Canada Ltd.

Please provide your views on the proposed XBRL taxonomy (intended to form the basis for supervisory data transmission between competent authorities and the EBA) and supporting documentation, and in particular on the technical expression of the ITS data point model in XBRL.
In the "EBA Architecture for XBRL Representation of DPM.pdf" document, page 8, it indicates that the role "http://www.xbrl.org/2008/role/verboseLabel" will be used to identify a "Definition" label. This appears to be a misuse of this role, which is defined in the XBRL Specification thus: "Extended label for a Concept, making sure not to omit text that is required to enable the label to be understood on a stand alone basis. ". A more appropriate role is provided in the XBRL specification, notably "http://www.xbrl.org/2003/role/definitionGuidance" which is defined therein as "A precise definition of a Concept, providing an explanation of its meaning and its appropriate usage.". This "hijacking" of the verboseLabel role will require standardised software to be customised for this taxonomy whereas if the appropriate role had been used such customisation would not have been necessary. The EBA is urged to use roles as designed and implemented in the XBRL Specification in order to be consistent with the philosophy of utilising a common standard.
Contact name
Hugh Wallis