The European Banking Authority (EBA) today publishes a questionnaire on the identification of users/investors needs on credit institutions Pillar 3 disclosures.
The questionnaire invites interested parties to comment on the issues/areas that users of Pillar 3 disclosures consider to be the most important from their perspective and that, accordingly should be the focus of the EBA’s 2012 assessment of Pillar 3 disclosures. This questionnaire will also allow to identify possible stakeholders for a future dialogue with the EBA on Pillar 3 issues once the analysis of the responses has been completed. It is expected that both the analysis of the submitted responses and possible meetings with interested parties will be performed and completed during the planning phase of the 2012 exercise.
It was felt that the value of the EBA’s output could be enhanced with extensive market outreach, dialogue with preparers and investors, and more generally consideration of what are the needs of the target users of EBA’s report assessing Pillar 3 disclosures.
Scope and structure of the questionnaire
The scope of the 2012 exercise is limited on disclosure areas where:
- improvements are still needed, based on the findings/conclusions of the 2011 EBA report (own funds, IRB, remuneration); and
- new requirements have been recently introduced (e.g. securitization, market risk), for which user feedback can reflect expectations regarding newly introduced CRD requirements.
The questionnaire is focused on the following three sections: i) identification, ii) a general assessment, and iii) specific disclosures.
The questionnaire invites users to lay down their views about how credit institutions articulate their Pillar 3 disclosures in the context of the current CRD framework. Users should refrain from proposing disclosures that are not currently required by the EU framework or from discussing the assessment of disclosures that will be implemented by future frameworks.
However, it was felt important to use this questionnaire as a tool for understanding how relevant and useful were the results and the best practices identified in the previous EBA assessments from a users’ perspective. Thus, the current survey includes questions on issues that go beyond the letter of the CRD and are mostly linked with disclosures EBA has identified as best practices. These questions are specifically marked as EBA best practices related questions. Views from users, also from the ones that don’t make extensive use of Pillar 3 disclosures , are particularly useful if they can be taken on board for this year’s EBA Pillar 3 assessment which is due to start in May 2012.
All responses to the questionnaire
have be published on the EBA’s website