Response to consultation to amend the ITS on procedures, forms and templates for resolution planning

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Question 1. Would the envisaged remittance date (31 May to be progressively advanced to 31 March) appropriate for all templates? If not, please justify your answer and indicate, template by template, the alternative remittance date you would suggest.

For templates that hold financial information on the firm, how will Financial Statements ('FS') external audit adjustments be recognised. For example if the relevant templates ie (R03.00) are reported on in March and in April it is identified that a FS adjustment is required, how should that be reflected on R03.00?

Question 2. Are there any technical obstacles or inconsistencies in the template ‘R 01.00 - Organisational structure (R-ORG)’ which would prevent you from, or make it disproportionate for you, to report the information required thereby?

For ‘Entity type’ included in R01.00, if multiple licences are held by a frim, how is this to be populated?
Can further definition be provided in the Instructions for ‘Share Capital’ within R01.00 (i.e. paid and unpaid)?

Question 3. Are there any technical obstacles or inconsistencies in the second block of templates (R 02.00 - Liability Structure (R-LIAB), R 03.00 - Own funds (R-OWN), R 04.00 - Intragroup financial interconnections (R-IFC), major counterparties, R 06.00 - Deposit insurance (R-DIS)) which would prevent you or make it disproportionate for you to report the information required thereby?

R02.00: can the following be included in the instructions, in the interest of industry participants:
The reasoning behind the inclusion of the detail (110-200), if these liabilities are not to be used in any case for Bail-In.
Given the difficulties that firms may have in getting detail on counterparties, the reasoning behind the split of counterparties (specifically 020 and 030).

Is it possible to have a minimum materiality level included in the specific templates (ie R02.00 and R05.01)?
Can an example be provided on the Instruction of what ‘Code’ is to be used for R05.01 and R05.02?

Question 5. The reporting of FMIs and information systems is already required since 2016. In practice are you operationally able to provide such view and do you think it is necessary to set a transition period, for example to progressively build up over the course of three years a full view of the systems within groups?

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Question 4. Are there any technical obstacles or inconsistencies in the third block of templates (critical functions and core business lines, R 08.00 - Critical services (R-SERV), FMI services, critical information systems) which would prevent you or make it disproportionate for you to report the information required thereby?

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Question 5. The reporting of FMIs and information systems is already required since 2016. In practice are you operationally able to provide such view and do you think it is necessary to set a transition period, for example to progressively build up over the course of three years a full view of the systems within groups?

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Question 6. The reporting of FMI services and enabling services, in templates R 09.02 and R 09.03 could be facilitated if a list of typical services was included. Can you suggest such list?

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Question 7. Does the nomenclature of information systems in template R 10-01 - Critical Information systems (General information) (R-CIS 1) cover the various types of existing systems, and would it in your view enable the authority to properly identify systems that are key in the performance of critical functions?

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Question 8. Are the granularity and content of the revised templates appropriate with regard to investment firms? If not, please develop specific changes you would suggest in relation to investment firms.

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Name of organisation

Gibraltar Resolution and Compensation Unit