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.
It seems that the implementation of P3DH has benefits in terms of comparability and transparency between banks. However, it will be good for the institutions to have, if not already planned, a testing phase as soon EBA published Final ITS on CRR 3.
Question 2: Would you agree with the specification to provide the information on remuneration policies separately? If not, please explain the reasons why.
There are benefits to include information on remuneration policies within the Pillar 3 Disclosures Report and not separately. By consolidating reports, organizations can reduce redundancy and ensure that all relevant information is presented in a single, comprehensive document. Including remuneration policies in the Pillar 3 report can provide stakeholders with a clearer and more complete picture of the organization’s financial and governance practices.
Question 3: Would you agree with the proposal on the collection of contact points information, including the suggested monthly frequency?
We agree with the proposal on the collection of contact points information, but we believe that the frequency should be quarterly at the earliest . We would like clarity on the data points (other than the contact points) that will be included in this template for further comment .
Question 4: Would you have any comments or suggestions on the most adequate profile of the contact persons within the institution?
We suggest a group (Heads and Managers) of contact persons rather than a single person. Contact persons profile can vary depending which department/s is/are responsible for the preparation of the Pillar 3 disclosures within the institution.