Response to consultation Paper on Draft Implementing Technical Standards on reporting requirements for investment firms under Article 54(3) and on disclosures requirements under Article 49(2) of Regulation (EU) 2019/2033
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8. Supervisory reporting
Draft ITS on reporting requirements for investment firms under Article 54(3) and on disclosures requirements under Article 49(2) of Regulation (EU) 2019/2033 – EBA/CP/2020/07
COREP templates for K- NPR (IF 06.09 – K-Net position risk - K-NPR additional detail)
8.1. FIA EPTA members note the EBA’s proposal that all firms subject to K-NPR will need to submit the COREP templates for ‘market risk’. We are of the view that this approach does not appear to be in line with the principle of proportionality that is intended to apply for the new prudential regime for investment firms.
8.2. In order to ensure greater proportionality in reporting, FIA EPTA members would ask the EBA to consider, to apply an approach where only firms for whom K-NPR is a material risk to have to submit the detailed COREP templates, while other firms would only need to submit a simplified K-NPR report. We suggest that this could be achieved, for example, by requiring the detailed COREP templates for firms where the K-NPR is larger than 20% of the investment firm’s own funds.
No materiality for resubmission (Article 3(4) – supervisory reporting and disclosures RTS_
8.3. According to the proposed delegated regulation, investment firms may submit unaudited figures. However, where audited figures deviate from submitted unaudited figures, the revised, audited figures shall be submitted without undue delay.
8.4. We note there is no concept of materiality for resubmission of regulatory returns, which can lead to a large number of resubmissions, implying an additional burden for firms and national competent authorities. FIA EPTA would suggest to the EBA that a more propor-tionate and appropriate approach would be to introduce a concept of materiality for re-submission of an investment firm’s regulatory returns.
Question 4: Do the respondents identify any discrepancies between templates IF 06.01 - IF 06.13 and instructions and the calculation of the requirements set out in the underlying regulation?
We refer to Section 8 of our attached consolidated submission.8. Supervisory reporting
Draft ITS on reporting requirements for investment firms under Article 54(3) and on disclosures requirements under Article 49(2) of Regulation (EU) 2019/2033 – EBA/CP/2020/07
COREP templates for K- NPR (IF 06.09 – K-Net position risk - K-NPR additional detail)
8.1. FIA EPTA members note the EBA’s proposal that all firms subject to K-NPR will need to submit the COREP templates for ‘market risk’. We are of the view that this approach does not appear to be in line with the principle of proportionality that is intended to apply for the new prudential regime for investment firms.
8.2. In order to ensure greater proportionality in reporting, FIA EPTA members would ask the EBA to consider, to apply an approach where only firms for whom K-NPR is a material risk to have to submit the detailed COREP templates, while other firms would only need to submit a simplified K-NPR report. We suggest that this could be achieved, for example, by requiring the detailed COREP templates for firms where the K-NPR is larger than 20% of the investment firm’s own funds.
No materiality for resubmission (Article 3(4) – supervisory reporting and disclosures RTS_
8.3. According to the proposed delegated regulation, investment firms may submit unaudited figures. However, where audited figures deviate from submitted unaudited figures, the revised, audited figures shall be submitted without undue delay.
8.4. We note there is no concept of materiality for resubmission of regulatory returns, which can lead to a large number of resubmissions, implying an additional burden for firms and national competent authorities. FIA EPTA would suggest to the EBA that a more propor-tionate and appropriate approach would be to introduce a concept of materiality for re-submission of an investment firm’s regulatory returns.
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