Response to consultation on draft ITS on supervisory reporting with respect to ALMM
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However, we detected the following issue:
The new line “1131 Outflows from uncommitted funding facilities” references Art. 23 (1) a, b, d and e LCR. Our current working assumption is that solely using the first time bucket is still an option. A subdivision per time bucket either would need additional data and business logic or is not feasible because facilities could be drawn on a daily basis. Hence, sticking to the specific example in 5.1.2 would counteracts the original idea of the change of a reduced burden of reporting.
Exempting entire reporting templates proved to be the most efficient way to enhance proportionality. Regarding the exemptions for medium sized banks, we also see the possibility to exclude C 68.00 and C 69.00 from their reporting requirements, as the funding profile does not differ significantly from that of SNCI.
Moreover, we ask for medium sized banks to take back the monthly reporting requirement, introduced with DA EU/2021/451. In our view, the increased reporting frequency introduced by the revised reporting regulation is not matched by a corresponding supervisory benefit in terms of the (continued) effort for the institutions. The quarterly reporting frequency has been sufficient to monitor medium banks since the introduction of the ALMM.
The planned changes in C 66.01 seem plausible. However, the examples for the mapping of derivatives are cases in which the bank receives securities as collateral – to our knowledge, this applies rather rarely to primary banks.
Question 1: Are the instructions and templates clear to the respondents?
YesQuestion 2: Do the respondents identify any discrepancies between these templates and instructions and the calculation of the requirements set out in the underlying regulation?
NoQuestion 3: Do the respondents agree that the amended ITS fits the purpose of the underlying regulation?
Yes.However, we detected the following issue:
The new line “1131 Outflows from uncommitted funding facilities” references Art. 23 (1) a, b, d and e LCR. Our current working assumption is that solely using the first time bucket is still an option. A subdivision per time bucket either would need additional data and business logic or is not feasible because facilities could be drawn on a daily basis. Hence, sticking to the specific example in 5.1.2 would counteracts the original idea of the change of a reduced burden of reporting.
Question 4: Do respondents agree that the decisions to exempt entire reporting templates from being reported is the best approach in implementing proportionality? In case you do not agree, what other proposal would be more efficient to reduce costs?
Yes.Exempting entire reporting templates proved to be the most efficient way to enhance proportionality. Regarding the exemptions for medium sized banks, we also see the possibility to exclude C 68.00 and C 69.00 from their reporting requirements, as the funding profile does not differ significantly from that of SNCI.
Moreover, we ask for medium sized banks to take back the monthly reporting requirement, introduced with DA EU/2021/451. In our view, the increased reporting frequency introduced by the revised reporting regulation is not matched by a corresponding supervisory benefit in terms of the (continued) effort for the institutions. The quarterly reporting frequency has been sufficient to monitor medium banks since the introduction of the ALMM.
Question 5: Is it clear for respondents how to report derivatives in C 66.01 with the new clarifications proposed in the instructions?
Yes.The planned changes in C 66.01 seem plausible. However, the examples for the mapping of derivatives are cases in which the bank receives securities as collateral – to our knowledge, this applies rather rarely to primary banks.
Question 6: Would large institutions agree that it is less costly to keep C70.00 unchanged (accounting also for implementation costs)? What would be a suitable alternative for a simplified version of this template which would achieve the same purposes?
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20210728_DK_EBA_ALMM_Cons_20212428.pdf
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