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.
Ad 3.1 of the Consultation paper - General considerations
Rec.25
We welcome the EBA's objective of providing corresponding mapping rules for all templates from the disclosure obligations. This ensures the consistency of information from regulatory reporting and disclosure. We would like to point out that appropriate mapping rules have not yet been made available for all disclosure templates. Mapping is not available for i.e. Template EU MR3, Parts of Template EU MR2-B, Template EU OR2, Template EU OR1 (2), etc. (Mapping Tool Version from 09th July 2024 -https://www.eba.europa.eu/sites/default/files/2024-07/24c3e503-f985-4785-b4ae-83766c54d01b/mapping_tool_all_templates_including_step_1_track_changes.xlsx [24.10.2024])
Rec. 26
We propose that the principle of proportionality should be considered exclusively through the different scope of quantitative and qualitative disclosure data requirements and not through the transmission channel. This could be achieved by deriving the quantitative disclosure data from the reporting data in a standardized manner analogous to the SNCIs for large and other institutions, while the qualitative disclosure is derived from the reporting data. The proportionality principle could be guaranteed by the distinction of the range of disclosure requirements.
We would like to point out, that the transmission channel/technical access to the submission platform is still not clarified (is the data uploaded/ how exactly does the interface to the data hub look like, etc.). This information is crucial for the planning of the technical implementation and in order to assess whether an implementation in a regulatory reporting software is meaningful or whether the disclosure templates are just uploaded for example.
Ad 3.2 - P3DH process for large and other institutions
Submission channel unclear (Rec. 30): To ensure that the required data can be submitted in time, the industry would need a detailed description of the access to the submission platform. This information should be available as soon as possible, but with the publication of the final ITS at the latest, so that the technical and organizational preparations can be made and to assess the best way of technical implementation.
Sign-off (Rec. 31, Rec. 32): We assume that the data review of the quantitative disclosure data must be carried out exclusively on the basis of internally defined processes and that there are no EBA requirements in this regard. The checks listed in the ‘technical validations’ section relate exclusively to technical, not content-related checks.
Data exchange formats
Rec. 35
The description of the disclosure content to be transmitted is understood in such a way that on the one hand the xBRL files, which contain the quantitative data, must contain additional qualitative information (the narrative) and on the other hand the pdf files must contain the complete quantitative data as well as a written attestation in imaging format. This preparation would not only lead to redundant provision of content in several formats, but also to considerable additional workload in processing, the benefits of which are not obvious. We would suggest receiving and processing quantitative data in xBRL-csv format and qualitative data in pdf format without redundancy. This would enable an efficient und simple preparation and processing process for institutions.
The aim should be to simplify, standardize and automate processes while maintaining high quality standards. Unfortunately, this goal cannot be achieved with the formulated requirements.
Information from institution’ contact persons
Rec. 42 and question 3 in 5.3 Overview of questions in consultation:
An additional template is proposed for the collection of contact information as part of the supervisory reporting system with a monthly frequency. In practical terms, this proposal would mean a new, albeit not complex, report to be submitted on a monthly basis. We are clearly against this proposal, as it would create unnecessary additional work for the collection of contact data. Instead, the data of contact persons should be updated by authorized representatives of the institution itself in the EBA portal in case of any changes.
Submission dates
Rec. 49:
The possibility for national competent authorities to adopt additional or deviating amendments on the basis of Article 106 of the CRD fundamentally contradicts the objective of achieving uniform standards of European requirements. It would be desirable to work on harmonized standards here, as is already the case with other initiatives.
Technical Validation – xBRL
Rec. 54:
The explanations make it clear that there will not be implemented any data checks by EBA. The review and quality assurance of the data is the sole responsibility of the institutions as data owners. The publication of validation rules planned as part of the DPM is to be regarded purely as a support service by EBA. We assume that the rejection of data files can only be related to technical format problems.