Response to consultation on draft ITS on supervisory reporting with respect to ALMM

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Question 1: Are the instructions and templates clear to the respondents?

Please refer to attached document.

Question 2: Do the respondents identify any discrepancies between these templates and instructions and the calculation of the requirements set out in the underlying regulation?

Please refer to attached document.

Question 3: Do the respondents agree that the amended ITS fits the purpose of the underlying regulation?

Please refer to attached document.

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?

Please refer to attached document.

Question 5: Is it clear for respondents how to report derivatives in C 66.01 with the new clarifications proposed in the instructions?

Please refer to attached document.

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?

Please refer to attached document.

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Name of the organization

European Association of Co-operative Banks