Response to consultation on draft ITS amending ITS on Supervisory Reporting with regards to COREP and asset encumbrance reporting
Go back
As already mentioned in our introductory remarks, we do welcome the exemption of fiduciary assets in the calculation of the Asset Encumbrance ratio. However, in the light of the underlying objective to reduce supervisory costs using proportionality measures we do suggest excluding indemnification (Haftungsfreistellung) of promotional loans. Especially for smaller institutions the asset encumbrance ratio is mainly driven by loans which are partially free from credit risk. This approach would better fit the purpose of the underlying regulation.
Question 1: Are the instructions and templates, as presented in the annexes to this consultation paper, 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?
Basically, yes.As already mentioned in our introductory remarks, we do welcome the exemption of fiduciary assets in the calculation of the Asset Encumbrance ratio. However, in the light of the underlying objective to reduce supervisory costs using proportionality measures we do suggest excluding indemnification (Haftungsfreistellung) of promotional loans. Especially for smaller institutions the asset encumbrance ratio is mainly driven by loans which are partially free from credit risk. This approach would better fit the purpose of the underlying regulation.