Division Bank and Insurance, Austrian Federal Economic Chamber
The disclosure for all institutions is not consistent with the principle of proportionality and would cause a big administrative problem for all small and medium sized institutions, particularly because under section 5 (1) item 9a and section 28a (5) 5 of the Austrian Banking Act there is only the obligation for institutions with important relevance (section 5 (4) Austrian Banking Act) to disclose them. We would encourage to except the small- and medium institutions for the disclosure of the number of directorships held by members of the management body under article 435 (2) a CRR and to apply the section 435 (2) lit a CRR only for institutions with important relevance.
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 significant additional expense und would be in no relation of additional benefit for investors. Therefore, we request to delete the word “semi” under paragraph 26 point a) third bullet and to demand the ITS on own funds disclosures and ITS on Leverage ratio disclosures only on an annual basis as required until now.