Response to consultation on draft Implementing Technical Standards on Pillar 3 data hub
Question 1: Do you agree with the proposed IT solutions that would support the implementation of the P3DH to Large and Other institutions? If not, please explain the reasons why.
We propose that the so-called other than large institutions that have not issued securities admitted to trading on a regulated market should be treated in the same way as small and non-complex institutions (SNCI). In many cases, other than large institutions (e.g. associate banks that associate cooperative banks that are SNCIs) may not have sufficient human and technical resources to analyse, complete and transmit the data, including the use of technical English, in the manner prescribed for large institutions of a systemic nature.
The inclusion in the reporting regime of other than large institutions that have not issued securities admitted to trading on a regulated market, such as SNCIs, will improve the reporting process and enable the EBA to deal with disclosed data based on information from supervisory reports submitted to the Polish Financial Supervision Authority.
In addition, we see a need to clarify the deadline for submitting data for institutions other than large ones that have not issued securities admitted to trading on a regulated market. These institutions are not obliged to publish quarterly financial statements. Therefore, please specify the deadline for disclosure, e.g. of the half-yearly information that has been prepared so far (to a limited extent - EU KM1 and EU KM2) and sent to the EBA.
In addition, we ask you to clarify the use of the visualisation tool by banks, as the current provisions of the RTS do not clearly define the scope of its use and the obligations of banks in this respect.
Question 2: Would you agree with the specification to provide the information on remuneration policies separately? If not, please explain the reasons why.
Yes, remuneration policy information may be provided separately.
Question 3: Would you agree with the proposal on the collection of contact points information, including the suggested monthly frequency?
In our view, the collection of data on contact points on a monthly basis is excessive for institutions other than large ones that have not issued securities admitted to trading on a regulated market. These institutions are obliged to disclose information on a semi-annual basis, therefore we propose to collect data on contact points with the same frequency (semi-annually).
Question 4: Would you have any comments or suggestions on the most adequate profile of the contact persons within the institution?
Disclosure of information is related to substantive risk knowledge on the one hand, and to the practical use of new tools introduced by the EBA on the other, and therefore also to IT knowledge. Therefore, if the indication of contact persons is related to questions and/or technical problems, which follows from point 41 of the RTS, it seems that the appropriate profile should be IT staff.