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European Savings and Retail Banking Group

In our opinion disclosure waivers and the assessment of the need for more frequent disclosures should be framed within a dedicated process. This process should be simple and focused in order to not overload institutions with new obligations. We would for example suggest that the waiver and the frequency policies could be part of the formal policy adopted by institutions to comply with the disclosure requirements laid down in Part Eight of the CRR, instead of an independent one.
We believe that the guidelines are sufficiently developed in this regard.
We do not believe that placing the same disclosure requirements on all institutions is consistent with the principle of proportionality. Ignoring size and complexity of the institutions places a big administrative burden on small and medium-sized institutions. In the Austrian Banking Act under section 5(1) item 9a and section 28a(5) 5 only institutions with important relevance (as defined by section 5(4) of the Austrian Banking Act) must provide full disclosures. We would encourage that Article 435(2a) of the CRR only applies to institutions with important relevance and that there is a specific exemption for small- and medium institutions from the disclosure of the number of directorships held by members of the management body.
Yes, we agree. We see no need for more elements to be considered.
We propose to replace the definition in paragraph 18 and consider instead whether the institution qualifies as a systemically important institution (as defined by the Single Supervisory Mechanism of the ECB), instead of the indicators mentioned in the consultation paper. We question strongly the inclusion of point d in paragraph 18 as we fail to see the importance of holding a larger foreign currency position in this context.
Article 432(1) of the CRR does not mention that institutions should provide information in case disclosures are omitted due to immateriality reasons.
Information has to be provided when information is assessed as proprietary or confidential (article 432(3)). We therefore consider that paragraph 19 of the consultation paper should be deleted.
The need for disclosing the full set of information required by Commission Implementing Regulation (EU) 1423/2013 (ITS on own funds) and the Draft ITS on Disclosure for Leverage Ratio under Article 451 (2) of Regulation (EU) 575/2013RTS on a semi-annual basis (instead of as before on an annual basis) for institutions meeting the indicator in point d) of paragraph 18, as described in paragraph 26 point a) of the CP on page 24, would cause a disproportionate additional expense on the reporting institution in relation to any perceived additional benefit for investors. Therefore, we ask that ask that these disclosures are required only on an annual basis as has been the case historically.
The proposed implementation date is January 2015. If this means that the disclosure obligation is in regards to information from 2014. If this is the case we would ask for a delay in order to provide sufficient time for institutions to comply with the new obligations (for example regarding the waiver and the frequency policies).
European Savings and Retail Banking Group